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Recommendations for resident in country with no CFC rules and territorial tax system

ModeCall

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Mar 11, 2020
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I'm a resident somewhere in Asia. In a country with a territorial tax system, plus no CFC rules (and no CRS, not that it matters). EU citizenship. I'm in the online advertising space. Think of e-commerce stuff and Facebook Advertising. Not adult, not pharma, not gambling, nothing like that.

I might be wrong (tips appreciated), but it feels like I am in a privileged position of being able to incorporate anywhere and pay 0% taxes, legally. However, in 2020 it seems like this option has become an extremely difficult task.

1️⃣ The first problem is, where to incorporate? Between newly introduced substance requirements, blacklists, etc. what remaining options are there? Perhaps BVI? Anything else? Hong Kong not a possibility due to clients being there.

2️⃣ The second problem is... where can such companies even bank nowadays? Seems like banking options are really really limited. Some providers offer Singapore, but I'm not sure what are the odds of getting approved. What else is out there for a jurisdiction like BVI (or whatever)? Forget about things like Euro Pacific or dodgy countries like Georgia or anything like that. Our revenue is quite high. I don't wanna wake up one day seeing our bank went bankrupt or the country next door decided to invade them, if you know what I mean. EMIs not considered for the same reason.

It also seems like taking funds out to personal accounts or making investments from a BVI (or similar) company is gonna be troublesome in the future. No one wants to deal anymore with the lack of transparency, no audits, etc.

➡️ What would you guys do if you were in my position?
 
Why not a US LLC as a disregard entity? You will get taxed as individual in your country but since your country has territorial taxation then in theory you won't pay taxes. With the LLC you will get easy access to stuff like Stripe, Braintree, Mercury, Transferwise, and if you go there even easier to get a bank account.

Also, if your incomes are high then why not pay an international business consultant? They will give you a better advise than us I guess.
 
Why not a US LLC as a disregard entity? You will get taxed as individual in your country but since your country has territorial taxation then in theory you won't pay taxes. With the LLC you will get easy access to stuff like Stripe, Braintree, Mercury, Transferwise, and if you go there even easier to get a bank account.

Also, if your incomes are high then why not pay an international business consultant? They will give you a better advise than us I guess.

I second this.

I might consider an LLC in Wyoming. With all of the docs, one should then be able to establish a banking relationship with a US bank that can include payment processing. The bank opening can sometimes be done remotely, but a trip to the US to satisfy KYC is probably better. Once you do KYC with a bank in person, you can usually open additional personal and business accounts in the future without needing to visit again.
 

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