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Recent content by Traveler

  1. Traveler

    Digital Nomad / Perpetual Traveller - 0% tax with US LLC

    The issue with the likes of Mr. Henderson and other non-lawyers whose very business is to sell these dreams (and not care about the consequences) is that while some of these structures may at first appear solid, they nearly unequivocally break apart in most real-world scenarios. Consider your...
  2. Traveler

    What Is Permanent Establishment?

    Good article! The one thing I'd suggest adding is that even something as innocent-looking as a rental apartment (or an AirBnb) can easily constitute a "fixed place of business". Especially in this day and age of digital nomads, many people think PE doesn't apply to them because "they just work...
  3. Traveler

    What documents I need to open a Business Account em BofA for SM Foreign Onwer Delaware LLC?

    In addition to what was said above, also note that lately it's been impossible to open if the individual representing the company (you) doesn't have an SSN, or at the very least, an ITIN. Many people I know have gone through this ordeal, turned away regardless of the state/branch they've...
  4. Traveler

    Easy (remote) EU personal banking

    Take Georgian banks off the list, unless you're planning to hold/move very small or very large amounts. Both TBC and Bank of Georgia have let go of their "foreigner client appetite" considerably, to the extent that your odds of establishing a successful relationship with either while not having...
  5. Traveler

    Tax-free residency in Estonia

    Estonia has both PE and CFC legislation present in its tax code (CFC as of recently), so the above isn't quite right.
  6. Traveler

    Where should I register a company selling SaaS worldwide?

    The vast majority of them evade tax. Pure and simple. Granted - some (most?) of them do it unknowingly, and a lot will fly under the radar forever (especially those whose income is insignificant). but that doesn't change the fact.
  7. Traveler

    How can I get an ITIN number for non US resident by myself?

    The service providers *may* help but avoid paying any fees until they've confirmed that they can help. And make sure they offer a refund in case your application gets rejected, as it's easy to file a BS application that the provide knows will get rejected and charge you $600 for it. The Amazon...
  8. Traveler

    How much would cost a consultation from one of the "big four" ?

    It depends largely on the branch/country. In a third-world country, you may be able to secure some consulting and basic work for a mid-4-figure retainer (if they accept you as a client, that is). But go to London or Zurich and you're almost certainly not going to be on a <$10-15k retainer.
  9. Traveler

    Georgia EMI license obtaining

    Well, welcome to Georgia ;) The same situation holds true for much, much simpler questions as well. The vast majority of "professionals" that you speak to in Georgia have their own, often very bizarre, interpretation of the law, and the culture here discourages anyone from saying things like...
  10. Traveler

    Companies made simple or similar

    You don't need to provide any document photos. The UK is one of the simplest jurisdictions in the world to incorporate in. That obviously doesn't mean that UK banks would suddenly be happy to have any dealings with you. Unless you have real substance in the UK, there's virtually no chance...
  11. Traveler

    Companies made simple or similar

    No. And you can also register directly with the Companies House through their web form. Incorporators like Companies Made Simple and a countless of others provide really no value. Apart from, perhaps, a legal address service, but for that you can also get a virtual address from elsewhere.
  12. Traveler

    Delaware company with a shareholder fiscally resident in Georgia (the country)

    Old thread, but this never got anyone's input so I figured I'd offer my 2 cents. The issue that your proposed structure triggers is Georgia's "substance over form" legislation. So in case of a "thin" setup, the tax authorities can easily (and successfully) argue that the foreign entity serves...
  13. Traveler

    For those who consider or have a bank account in Georgia

    Deposits with TBC are problematic to begin with. For non Private Banking clients, you need to physically visit a branch to even open one. I suspect the same will then be true for terminating it. Sending funds out of Georgia is rarely a problem. The banks here are far more likely to give you...
  14. Traveler

    For those who consider or have a bank account in Georgia

    Yep - this is super annoying. Especially as your deposits won't even break upon expiry, but rather automatically renew for another (shorter) period, usually at a lower interest rate than the original, unless you specifically terminate it. The situation is much better with SOLO (their version of...
  15. Traveler

    Globally - New residency program for remote workers

    Just to chime in here, Georgia's "Work Remotely from Georgia" scheme has no tax benefits, nor any immigration-related benefits. It's simply a programme that lets one bypass the additional temporary entry restrictions that were established due to COVID-19. The legislation is actually very...