SCP shield you from any US inheritance tax in case any of your business touches US - Monaco SCP is a very cheap wrapper.
If inheritance is not a concern, then could just use the US LLC.
I don't see personally any need for a guernsey company (unless he wants to own these assets through a trust -...
1) You don't need the guernsey setup
2) I would suggest you setup a Monaco SCP (it's a transparent company, civil company - so not taxed), check-the-box to make it opaque for US tax purposes
3) make the monaco SCP own the US LLC
I would be curious on how your setup went!
What are the costs for these services and most importantly, do you think they are really a workable solution to prove "substance"?
I am not sure how much corporate services can be considered substance..
Sorry, BVI wont work with participation exemption, it must have a DTT with italy.
Romania might not impose, but the individual must pay 26% in Italy on any dividend they receive.
Note that 26% is on the final gains whenever you want to distribute the $$ in the company, ideally you never do that and you take loans against it or you pay some deductions..
If you do your setup Marzio, you end up paying the 26% anyway in the form of dividend tax at the personal level. The...
the only legal way for you to do this and save taxes is:
* Setup an italian SRL
* Setup a foreign company, let your SRL be the shareholder of this company and have other people (directors + employees) running it from a favourable jurisdiction (ideally with a DTT with italy) with office bank...
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