The substance will be in Guernsey for example, US LLC just as subsidiary of Guernsey company, because there are better Payment Gateways for USA than for offshore countries.
That would work. How about a US MSB that is not connected to the offshore company? MSB licenses are easy to obtain (with $5-20K to spend, depending on registration type, your involvement and effort and the state) and you'd only need 1 state served since you would only onboard yourself as the client, i.e. the US MSB would be a regulated (which doesn't actually mean it does much) payment processor for the offshore company. You would avoid any consequences of US substance and taxation while reaping the benefits of US banking and payment processors and the 0% tax rates. There are no rules against MSBs providing remittance services via payment processing solutions or to offshore companies! To the US, you are still, at least for now, a non-resident alien with a FinCEN-registered company.
This approach might seem a bit far-fetched, but you gain quite a lot from it. Your offshore company will no longer have any requirement for transactional banking. All it needs is to at some point be remitted the funds according to its payment processing contract. You have little to no legal implications, yet you offer a regulated service (to yourself).
The only thing you will then need is for the offshore entity to send you and whatever employee payments and potentially invest its money (it doesn't really matter, but it makes the banks happy). Banks would rather onboard the "holding" of a Monagesque citizen that will only receive payments once in a while (and from the US) and sends a couple payments to individuals while making the money some nice fees on basic investments (why not?). The largest potential issue would be the fact that the US company would be holding the funds for some time, which a remittance provider is not supposed to do. But, if you find a bank for the offshore business that would not be so monkey-like as to just want to collect fees on investments, you would not necessarily experience an issue with releasing the funds.
Based on the general laws regarding MSBs in the US, this should be an applicable setup. In practice, I would say it is an achievable task, but definitely requires consultation with some lawyers.
DTAs for if in future i move to an agressive tax country (example Spain), the money go through DTAs. So, less headaches.
Makes sense, but I would never do that. Never lived in one, hopefully never will live in one (and I'd sacrifice my EUSSR citizenship if it meant paying taxes regardless of my residence, something like in the US).
I will check the option for LU banks. Looks like a reputable jurisdiction to maintain investments. Thank you so much for information, it's very valuable.
Yes, they do a good job for corporate banking. I presume you can keep your individual wealth in Monaco, I have not worked with the banks there. I have experience with LI, LU, CH - MC is on a different level for me maybe - I'm not a fan of spending much money on generic living costs.
Oh, i can't use EMI for business. Turnover is mid-range 7 figures. Expecting go to 8 figures soon (maybe next year).
There are still definitely EMIs that can handle such a scale, but far from an abundance. Good EMIs are scarce, but that does not mean they can't serve large-scale businesses.
EDIT: Also, I forgot to mention, whether you consider Guernsey or the BVI, Vistra will still probably be the best for this. I was checking some of my past communications there, where I also found that they assist with creating full substance in both of these countries after corporate registration. In that case, maybe you would not struggle as much with finding suitable employment options there. In addition, they also offer directorship services with people involved in a specific space - it can be of additional benefit.
