Did you try Panama Private Foundation as Holding?

[SaaS]

If you have experience with using panama private foundation as a holding company for US LLC and UK LTD please share and give advice, how was getting bank account for LLC and LTD? Also what about EIN and Forms 5420 and 1120?

Thanks

 

[Sols]

Unless you have a very good reason for doing it and are very confident in your ability to find banking for the structure, I wouldn't recommend it. Banks don't like it.

 

[Onassis]

If you have experience with using panama private foundation as a holding company for US LLC and UK LTD please share and give advice, how was getting bank account for LLC and LTD? Also what about EIN and Forms 5420 and 1120?

Unless you have at least $1M - forget about it. Using a US LLC with a foreign legal entity as a member is also not a good idea due to the branch profits tax. However if you insist on using a US LLC I think this could be solved by using a trust instead of a foundation.

Look into UAE - it might be better to just set up everything there, with substance and local banking of course. So an ADGM/DIFC foundation + FZCO. An alternative would be to have an independently owned OpCo which would lease assets from a foundation, although I'm not sure if that would work in practice.

What's your tax residency btw? As Martin said a few months ago all structures in 2023 need substance, however a foundation is a problem by itself as some countries don't recognize foreign foundations at all. So it is not only a tax but also a legal issue. And if you need to go with a Liechtenstein foundation (due to DACH residency for example) costs can go up quickly.

e.g.

https://blumgrob.ch/wp-content/uploads/2021/11/Recognition-of-foreign-family-foundations-in-Switzerland.pdf

Foundations also differ between jurisdictions which needs to be taken into account of course. See this for example: https://www.ius.uzh.ch/dam/jcr:2c894a3c-b7d7-4f9d-ac0d-d514a3349dbb/Noseda_Common Law Foundations - A Successful Experiment.pdf

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[aiello]

Unless you have at least $1M - forget about it. Using a US LLC with a foreign legal entity as a member is also not a good idea due to the branch profits tax. However if you insist on using a US LLC I think this could be solved by using a trust instead of a foundation.

Look into UAE - it might be better to just set up everything there, with substance and local banking of course. So an ADGM/DIFC foundation + FZCO. An alternative would be to have an independently owned OpCo which would lease assets from a foundation, although I'm not sure if that would work in practice.

What's your tax residency btw? As Martin said a few months ago all structures in 2023 need substance, however a foundation is a problem by itself as some countries don't recognize foreign foundations at all. So it is not only a tax but also a legal issue. And if you need to go with a Liechtenstein foundation (due to DACH residency for example) costs can go up quickly.

e.g.

https://blumgrob.ch/wp-content/uploads/2021/11/Recognition-of-foreign-family-foundations-in-Switzerland.pdf

Foundations also differ between jurisdictions which needs to be taken into account of course. See this for example: https://www.ius.uzh.ch/dam/jcr:2c894a3c-b7d7-4f9d-ac0d-d514a3349dbb/Noseda_Common Law Foundations - A Successful Experiment.pdf

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I know quite few people operating with US llc owned by a Panama foundation, what's branch tax are you referring to?

 

[daniels27]

I think this one

United States - Corporate - Branch income

Detailed description of corporate branch income tax rules in United States

taxsummaries.pwc.com

But is this an issue for a US LLC that is not engaged in a US trade or business?

 

[belarus]

I know quite few people operating with US llc owned by a Panama foundation, what's branch tax are you referring to?

any anonymous benefits from doing so or asset protecting benefits?

 

[daniels27]

any anonymous benefits from doing so or asset protecting benefits?

Yes, probably less tax risk than holding the US LLC personally and more flexibility in general as you can control when to get your much salary/dividends/profit in your personal account. But what about the branch profit tax problem?