Recent content by Mark Ross

barred blacklisted countries, if you declare the foreign dividends on your local global income declaration (in Italy it is called "modello 730", in Romania it is called "Declaratie de Venit Global") and you pay the taxes described in the anti double taxation treaty, no, you actually have no...

then Romanian micro-enterprise tax (3% on income) + Romanian dividend income (5%) + your country's individual income tax on foreign dividends based on the double-treaty tax with Romania (for most EU countries it is in the region of 15%,). You might still end up better off than using a domestic...

I thought I read you are Austrian... if I am wrong, ignore the "Vienna/Salzburg" detail but the rest of my comment remains valid

yes, of course. But on a personal level we are talking about a fully european country (/lifestyle), with two low-cost flights a day to Vienna and (I think) 5/week to Salzburg, with a large community of expats of all ages.... By a company standpoint, you are issuing invoices from an EU...

Romanian micro-enterprise. 3% income tax, minimal overhead costs and - if you decide - very easy to become a legal (and fiscal) resident, thus paying only 5% taxes on dividends (it is going to be more if you maintain your fiscal residency in Austria) Contact me if you want to discuss more.

I have the feeling that basing your offshore strategy on the ignorance of the bureaucrats is a thing of the past, unfortunately :) ...

At this time, moving to GE would be an option. The issue is that my main client (EU-based LTD) will require a certificate of fiscal residency of my entity in order not to retain (quite heavy) taxes in this country. As you clarified (and - after your comment - I found the same info here IRS Form...

yeah, but it would be kinda shooting yourself in the foot...

yes, you are right. I misconsidered a Delaware LLC as similar to a European SRL/SARL/LTD/GmBH. In Europe a LTD is one entity and its suppliers are independent entities, each with its own taxes (of course, with lots of exceptions). I understand now that a US LLC is more similar to a European...

The services would not be executed in Georgia. Alas, @JustAnotherNomad explained what the hole in my logic is. I now see that a US LLC is more similar to a "self employed" than a "company"

Understood. That was the part I missed and my scheme falls apart. Thx anyway...

Not really. Both my former and my current accountants are mediocre.

I would see no reason to pay a salary as long as all the profit of the LLC could be transferred as dividends to a personal account of the Georgian resident shareholder with (as far as I am understanding) zero tax implications. These dividends would be declared in the personal tax declaration in...

Thx for your input. Why do you think the LLC would not get a US tax residency certificate? In my opinion the Delaware LLC is in reality a fiscal resident of Delaware (otherwise it would have to pay income taxes in the country where it is fiscally resident). It is a fully fledged US entity...

Hi, I would like some opinions on this scheme 1. a Delaware LLC generates some income for consulting services executed for EU beneficiaries (companies) 2. the Delaware LLC is owned by a person who is fiscally resident in Georgia (the country, not the US state) In my opinion: - the Delaware LLC...