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Cyprus personal non-dom tax residence & US LLC w/ 0 tax offshore intermediary

ecommerceoffshore

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Mar 7, 2024
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Hi all.

Anyone know of a good 0% or territorial country where one can make a shell corporation own a non ETBUS E-commerce US LLC, then the US LLC pays this corp, which then distributes to a Cypriot Non Dom the dividends? I'm wondering on recommended countries to do this where the tax is zero, there are few "gray areas" and banking / wires are relatively simple? It seems like all of the 0 tax countries are on the EU black list, but what does this even mean? Does it matter if they're on a black list? Does this just mean no one will send or take wire transfers from them? If so, isn't it easy enough to just use Wise / Revolut to send, or even just keep the money in those platforms?

I am considering Panama but it is somewhat unclear whether they withhold foreign dividends (5%?), and whether US LLC e-commerce income is necessarily considered from abroad, given this definition from KPMG:

Taxable income is defined as income produced, from any source, within the Panamanian territory, regardless of the place where the income is received. Deviating from the territoriality principle, Panamanian tax laws also consider as taxable income any income that, even when derived from acts or services rendered abroad, benefits individuals or legal entities residing in Panama and relates to the generation and continuance of their Panamanian-source income.

Other countries I have heard of using are BVI, Seychelles, UAE, Nevis, Bahamas....

Anyone with any knowledge or experience on which country(s) could work as a proper 0 tax shell company, I would be so grateful.

Thank you!
 
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