Recent content by SmartestSmarty

I'm just coming back to this, just to confirm with you, because I am still interested in this set up. Why does the IRS treaty with Romania say the royalties can be taxed in both. I need to be fully confident Romania wouldn't want to tax me as well. It does say it's allowed to be taxed in both...

Thank you. What would be your suggestion?

I see, thanks for mentioning it. I’ll seek advice.

Well this is the first time I have heard about them, so this was not something I had discussed. It seems that the CFC rules are for bringing a foreign owned entity in to chargeable gains in the UK, but these gains are to be charged in the UK anyway. The only thing that is controlled is the...

This sounds like an option to look in to. Thanks. Any suggestions on jurisdictions or a good place to begin my search?

That is what I was told, I think the accountant is also an international tax specialist especially in single member foreign owned LLCs. So if this is the case, then this would be a decent solution. Yes I think a trust (is essentially a form of intermediary) I was considering this as an...

From what I read a qualified intermediary is a financial institution and non-qualified intermediary is not. An intermediary can be an agent, which is not a financial institution. After speaking with an accountant in the US, he said I can use a disregarded LLC incorporated in the USA to receive...

No I didn’t say use a UK LTD to transfer royalties to a company in Gibraltar. If I was not clear, what I was saying is: A company incorporated in Gibraltar, to act as an agent, to collect the royalties on my behalf (the beneficial owner) to then pay tax in the UK on the royalties received from...

I read through that, I cannot seem to work out the reasons why it would not be allowed. At least if someone else if owner of the company in Gibraltar, but even if it were myself. Can you explain why it doesn't work?

I was considering Gibraltar. In the tax act they have no tax on foreign sourced income under an LTD, but this does not apply to royalties, unless it is an intermediary. IRS allow for non-qualified intermediaries to act as withholding agents, and use the beneficial owner to determine the...

I’m not looking for methods by which ‘I won’t get caught’. An ltd in the UK will work out tax wise almost exactly the same as just paying tax as an individual. When you had up corporate tax + dividend tax. This is what im trying to work out, you don’t lose treaty benefits as the beneficial...

I am in the UK, I receive some royalty income from the US, under the double tax treaty there is no withholding tax. But I am then taxed on the full amount in the UK. I simply want to find the most appropriate method of limiting my tax exposure. I do not seek to evade tax, I want to be...

Hello all, I have a question about single member LLCs. As these are not considered for federal tax purposes, do they allow the receipt of the revenue by the LLC to be paid out later in the form of dividends, or as they are disregarded, is it expected that all revenue is received immediately by...

Hi all, I want to incorporate a company in Gibraltar to receive royalty income. However, is it true that although income from outside of Gibraltar is untaxed, royalties will be regardless of where they come from? What if I do not remit them to Gibraltar, are they then untaxed under the company?

Thanks, I know the company will be taxed wherever I am resident/manage it from. But what I am keen to understand, is on the US side, if the income from outside of the US is potentially taxed there by either the state or the IRS. Hopefully the answer is NO.