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Recent content by seabreeze

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    Question Where is the least regulated Collective Investment jurisdiction?

    Greetings fellow offshorecorptalkians ! I am working on a project where an unregulated, unregistered "fund-like" entity needs to be "legalized". Most "investors" have contributed small amounts. Are there any "obvious" jurisdictions which don't regulate collective investments (or don't define...
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    CFC rules in Georgia

    Sorry just saw this. As of now, Georgia is outside scope of interest for me in regard to Crypto. Kind regards
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    CFC rules in Georgia

    Pleasurable reading material, thank you.
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    CFC rules in Georgia

    I am perplexed why you'd want to do that in either Georgia OR UAE at all?! If it's professional investors (either proven or investing over 100k a pop), you can do whatever the hell you like in Luxembourg. Hell, you can even issue bankable securities and market-list them fin-regulation-free...
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    CFC rules in Georgia

    I wouldn't bury Georgia just yet. It's just Georgia is not a one-size-fits-all solution. Georgia traditionally has a territorial tax system, it's not just a whim and won't go away as such. I don't see anyone specifically specifically targeting territorial tax systems as a thing, and not that of...
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    Belgium dividend withholding tax to UAE resident individual

    Definitely make sure you check this with a Belgian tax attorney first. Especially that Belgium recently went utterly haywire in terms of liquidation taxation for individuals, exit taxation for corporates and anti-avoidance. Your move to UAE isn't particularly notable. Nor is your willingness to...
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    tax solution for small business (30K profit)

    Thank you. I too am stunned by the incessant incorrect use of CFC and PE concepts... I humbly suggest that @Admin could introduce some sort of quiz on basic terms during signup :D .
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    Incorporating a cryptocurrency hedge fund in Singapore as a Thailand resident

    Sponsoring an employment pass and living in Singapore is an option, but you'd need to have a couple of year's salary and running costs on account balance first. By virtue of your living in Thailand, the Singapore Co. does not automatically become liable to tax or is not automatically tax...
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    CFC rules in Georgia

    You don't need an LLP if your LTD is not UK tax resident. Just saying. Tax domicile UK LTD. in Georgia and get Virtual Zone status (must check but should be possible)? Nomad worry-free (5% profit distribution tax) thereafter.
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    CFC rules in Georgia

    @khinkali There has to be a point where one just gives up. I think there's plenty of info remaining in this thread for those who bother reading into it ;).
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    CFC rules in Georgia

    Your attitude regarding the "Georgian tax man verifying something" is plain wrong. If there is any tax suspicion, the burden of proof is on you, buddy. 1) What does the definition of a generally accepted international taxation concept have to do with Georgia? If you can't figure this out, you...
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    CFC rules in Georgia

    Re: One month in Dubai - That is, unless, you are engaged by the Dubai client when in Georgia as a Georgian self-employed person.
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    Straw man secret bank account?

    Uh-oh. I see what's happening here. Meds. Don't forget to take them.
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    CFC rules in Georgia

    Correct, it mentions three months. I quote: 4. Notwithstanding the provisions of the first and second paragraphs of this article, a permanent establishment of a foreign enterprise in Georgia shall be the management of this enterprise by another person (another enterprise, subunit of this or of...
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    CFC rules in Georgia

    That is international taxation 101. Income is deemed sourced in the location where the actions leading to the generation of said income took place.