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Question Help in choosing the best location

Caroltxr

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Apr 7, 2022
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Hi,

I’m a Brazilian citizen looking to invest on the American financial market ( stocks, founds etc). If taking into account secession laws and avoiding taxing, I would like to know from you guys opinion, if better to open a company under my own name on BVI or SEYCHELLES ?
Also could you recommend a website to help me set it up?
 
Hi,

I’m a Brazilian citizen looking to invest on the American financial market ( stocks, founds etc). If taking into account secession laws and avoiding taxing, I would like to know from you guys opinion, if better to open a company under my own name on BVI or SEYCHELLES ?
Also could you recommend a website to help me set it up?
Offshoring is way more complex than just clicking stuff on an order form and thinking that's it...

What is your goal here? Why do you need a corporate vehicle for this? Are you trying to avoid Brazilian taxes?

Please familiarize with these terms: Permanent Establishment, CFC, UBO, CRS, FATCA, Tax residency

Those will give you an idea of what's possible and what's not.

If you just want to invest in American securities, you can do so through various brokers e.g. Interactive Brokers and so on. No need for a complex setup like this.
 
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Offshoring is way more complex than just clicking stuff on an order form and thinking that's it...

What is your goal here? Why do you need a corporate vehicle for this? Are you trying to avoid Brazilian taxes?

Please familiarize with these terms: Permanent Establishment, CFC, UBO, CRS, FATCA, Tax residency

Those will give you an idea of what's possible and what's not.

If you just want to invest in American securities, you can do so through various brokers e.g. Interactive Brokers and so on. No need for a complex setup like this.
Hi,

Thank you very much for your reply and I’ll look into the topics.

I need to Establish an offshore company To avoid taxation of any profit made in my investments in the US. Also for succession purposes.

Hi,

Thank you very much for your reply and I’ll look into the topics.

I need to Establish an offshore company To avoid taxation of any profit made in my investments in the US. Also for succession purposes.
I am aware of the advantages of having an offshore compared to the tax structure of my country and I believe it’s worth it. I truly would like to know if because Seychelles is often on the black list of eu if it will impact big banks and investment founds accepting capital from my offshore. And would love to get Rec of an agent to help me to set up an offshore
 
Hi,

Thank you very much for your reply and I’ll look into the topics.

I need to Establish an offshore company To avoid taxation of any profit made in my investments in the US. Also for succession purposes.
This will unfortunately be very hard to do, especially considering such vehicle would be classified as a "Passive NFE". A lot of people would love to do this, but governments are not stupid and they've cracked down on the offshore industry these last 2 decades.

Can you give us an idea of how much money we're talking here? 100k+ 500k+ 1m$+ 5m$+? Because unless you are above a certain threshold, you should forget about this as it will be way more expensive than what you'd be paying as taxes.
 
This will unfortunately be very hard to do, especially considering such vehicle would be classified as a "Passive NFE". A lot of people would love to do this, but governments are not stupid and they've cracked down on the offshore industry these last 2 decades.

Can you give us an idea of how much money we're talking here? 100k+ 500k+ 1m$+ 5m$+? Because unless you are above a certain threshold, you should forget about this as it will be way more expensive than what you'd be paying as taxe

As long as the money leaves Brazil with taxes payed and doesn’t come back to its source ( there the need of an offshore) by investing in the us, the profit I’ll generate there through the stock markets / financial/ crypto Wont be taxed ( as long as I don’t repatriate the money). I have several passports and possibility to live in different locations and wouldn’t need to bring this money back. The idea is to leave some of my patrimony here and diversity through the us financial market portfolio, the money made abroad - avoid taxes. And also very importantly, for succession reasons, you get amazing advantages on taxes.

The initial start amount would be 2M usd.
 
As long as the money leaves Brazil with taxes payed and doesn’t come back to its source ( there the need of an offshore) by investing in the us, the profit I’ll generate there through the stock markets / financial/ crypto Wont be taxed ( as long as I don’t repatriate the money). I have several passports and possibility to live in different locations and wouldn’t need to bring this money back. The idea is to leave some of my patrimony here and diversity through the us financial market portfolio, the money made abroad - avoid taxes. And also very importantly, for succession reasons, you get amazing advantages on taxes.

The initial start amount would be 2M usd.
Thanks, I'm starting to see it a bit more clearly now.

Could you tell what citizenships you hold and where do you spend your time? E.g. 60 days in country X 180 days in Y etc. This is crucial for offshoring, if you can spend a certain time in a certain jurisdiction, you could actually pull this off. Also with that amount of capital this could be a bit more realistic. But it will be complex as this would not be an operating company but a passive vehicle.

I'll try to think of something or perhaps tag a few people who could help you.
 
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Thanks, I'm starting to see it a bit more clearly now.

Could you tell what citizenships you hold and where do you spend your time? E.g. 60 days in country X 180 days in Y etc. This is crucial for offshoring, if you can spend a certain time in a certain jurisdiction, you could actually pull this off. Also with that amount of capital this could be a bit more realistic. But it will be complex as this would not be an operating company but a passive vehicle.

I'll try to think of something or perhaps tag a few people who could help you.
Thank you so much much!!!

I hold Brazilian, Israeli, Canadian and European. My citizenship base taxation is Brazil. As for the time I spent on each it’s completely up to me. My work obligations are mostly remote
 
Thank you so much much!!!

I hold Brazilian, Israeli, Canadian and European. My citizenship base taxation is Brazil. As for the time I spent on each it’s completely up to me. My work obligations are mostly remote
Okay, great.

Would you be willing to relocate? Or at least, make it so that you only conduct altering your investments etc when you are in a specific jurisdiction?

I'm not sure how easy it would be to pull this off, but if you can, the best would probably be to setup a company in a jurisdiction with either 0 tax or no capital gains (CGT) tax, and then appointing an "asset manager" to manage your portfolio when you are not inside that jurisdiction, but again, I'm not sure if this would be enough for a passive entity like it would be for an operating company.

I will tag a few people here who can give their opinion:

@CyprusLawyer101 , He specializes in Cyprus, a no CGT jurisdiction, maybe he can give you a bit of insight on this as I'm sure he's had people ask this before.

@Fred , he specializes in establishing Dubai Free zone companies, 0% tax and you can get banking there quite easily along with residency so that you are officially a resident of Dubai. You should always spend enough time in Dubai to maintain this status.

@CaptK
 
Okay, great.

Would you be willing to relocate? Or at least, make it so that you only conduct altering your investments etc when you are in a specific jurisdiction?

I'm not sure how easy it would be to pull this off, but if you can, the best would probably be to setup a company in a jurisdiction with either 0 tax or no capital gains (CGT) tax, and then appointing an "asset manager" to manage your portfolio when you are not inside that jurisdiction, but again, I'm not sure if this would be enough for a passive entity like it would be for an operating company.

I will tag a few people here who can give their opinion:

@CyprusLawyer101 , He specializes in Cyprus, a no CGT jurisdiction, maybe he can give you a bit of insight on this as I'm sure he's had people ask this before.

@Fred , he specializes in establishing Dubai Free zone companies, 0% tax and you can get banking there quite easily along with residency so that you are officially a resident of Dubai. You should always spend enough time in Dubai to maintain this status.

@CaptK
Absolutely. They would be ok.

Thank you again !
 
Absolutely. They would be ok.

Thank you again !
No problem. Ask away if you have other questions or if you get proposed something, just to double check.

I'd also still ask local tax lawyers to make sure you won't get any nasty surprises down the road.

I'd also like to add a few jurisdictions/vehicles/etc that you may have not thought about:

Luxembourg Investment Vehicles: https://assets.kpmg/content/dam/kpmg/lu/pdf/luxembourg-regulated-investment-vehicles-2018.pdf

Netherlands (No CGT)

Luxembourg I know has a lot of private banking and asset management so this could be an option, but it could be quite expensive... But it's a very good jurisdiction so I'd take a look at it. These afaik don't or have minimal tax.
 

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