Best holding company for US LLC?

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ppa

New member
I have an US LLC that is owned by a Seychelles IBC. The IBC acts as a holding company. Reason being so that profits from the US LLC end up in the Seychelles IBC and only when needed distributed as dividends to the UBO.

UBO pays dividend tax. UBO can not own the US LLC directly (tax treaties and uncertaincy over how local tax authorities will treat the pass-through US LLC - Corporation? Personal Income? etc.)

As long as the UBO owns the US LLC through a holding company and due to the lack of CFC rules in his country of residence everything is good.

However Seychelles has introduced tax on passive income. Income from the US LLC is considered passive income for the Seychelles IBC so that setup is no longer good.

What are the options to replace the Seychelles company in this setup? The requirement is to open company + bank account at the same time? I guess there are a couple:
- BVI
- Nevis
- Panama
- UAE/Dubai

Any recommendations here on what would be the best setup are appreciated. Stability of the setup, ability to open a bank account, no reporting/audit stupidy (the way Seychelles has introduced) are the most important factors here. Cost is not an issue.
 

startfleetio

Active Member
I have an US LLC that is owned by a Seychelles IBC. The IBC acts as a holding company. Reason being so that profits from the US LLC end up in the Seychelles IBC and only when needed distributed as dividends to the UBO.

UBO pays dividend tax. UBO can not own the US LLC directly (tax treaties and uncertaincy over how local tax authorities will treat the pass-through US LLC - Corporation? Personal Income? etc.)

As long as the UBO owns the US LLC through a holding company and due to the lack of CFC rules in his country of residence everything is good.

However Seychelles has introduced tax on passive income. Income from the US LLC is considered passive income for the Seychelles IBC so that setup is no longer good.

What are the options to replace the Seychelles company in this setup? The requirement is to open company + bank account at the same time? I guess there are a couple:
- BVI
- Nevis
- Panama
- UAE/Dubai

Any recommendations here on what would be the best setup are appreciated. Stability of the setup, ability to open a bank account, no reporting/audit stupidy (the way Seychelles has introduced) are the most important factors here. Cost is not an issue.

Check out UK LTD. HMRC regards US LLC profits as dividends most of the time. Foreign dividends are tax-exempt until a certain threshold
 

fshore

Entrepreneur
uncertaincy over how local tax authorities will treat the pass-through US LLC - Corporation? Personal Income? etc.)
Is there any uncertainty over how the local tax authorities will treat a Seychelles/BVI etc company (that you own and manage from there)?
 

ppa

New member
No as the Seychelles IBC is not a pass-through entity + no double tax treaty between country of residence and Seychelles + multiple official tax advices from Law/Tax companies regarding the setup and its tax implications in the country of residence.
 

fshore

Entrepreneur
no double tax treaty between country of residence and Seychelle
Generally a double tax treaty is always positive. It would almost never cause you to pay more tax somewhere, it will always reduce the taxes you'd have to pay.
 

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