Indeed ... as pointed out earlier in this thread you are not home dry until the beneficial owner is resident somewhere with territorial taxation ... or where for some other reason you do not get taxed.Cool
But form 5472 is a dangerous. Have you seen the questions? It provides more detailed information than even CRS will ever do. If it ever came to a situation where IRS shared that data with your home country your finished....
P.S I have zero dealing with U.S as many of you know but the topic is interesting. What will IRS do with that data on disregarded entities? They are part of J5 now so information is shared.
You don't need to file 1040nr if you don't do business in the US. Only 1120 Pro forma with 5472.if just looked at the single member protection, then Wyoming is the better choice. Because in Florida you need multi members.
If you can get a bank account for your Wyoming company (in the USA!!) then you will have lots of fun with your Wyoming company. But since now I don't know any non-US Citizen who achieved this in Wyoming.
@fshore yes, you are right, checked with my accountant guy. You also need to file 1040NR along with some minor fillings, however there can be used estimates and it is almost impossible to be fined for having wrong estimates. They only want to see that you are not doing business in the US, that's all. They won't check an offshore company where they can't get tax from, so every audit would be a loss. The accounting laws in Florida make it easy to book almost everything without bills/invoices so normally a good offshore provider does this accounting tricks for you and you don't have to care about anything and don't need to collect invoices and bills. Sorry for my wrong text I hereby change my "no accounting" answer to "no real accounting needed, because the IRS doesn't want to see bills/invoices"
@Martin Everson form 5472 is only dangerous if no nominee is used. That always should be rule no.1 to use a nominee
The US is welcoming black money with open arms? Now I heard everythingKeep in mind, the US is in a currency fight which will go on for the next decade, they are trying to bind as much money as possible in their country, this is why they are welcoming black money with really wide open arms.