Samoa, BVI, Marshall Islands, Seychelles or another Country for Zero Tax Remote Opening of an Offshore Company?

[OCT2023]

Looking to open an offshore corporation in a zero-tax country remotely.

Found a service that recommends Samoa, BVI, Marshall Islands or Seychelles.

I plan to go 50/50 with my Non-US wife in order for the company to not be subject to US Taxation.

The service also offers to help apply for remote banking in Belize, BVI, Hong Kong, Mauritius, Singapore and Switzerland.

This would be a professional services business with international deposits and withdrawls along with Debit/ATM usage. No Merchant Services are used.

Do any of the countries and bank locations sound feasible for a US Citizen / Non-US Spouse planning to live outside of the US?

Thanks much!

 

[SCI]

US Citizen is headache for banking.
Do either of you reside in the US?

 

[Sols]

If, after careful research and advisory from qualified professionals, your shortlist is Samoa, BVI, Marshall Islands, and Seychelles, I'd go with BVI.

Make sure that your chosen service provider is licensed in BVI or, lacking that, a reputable service provider.

Banking and taxes are going to be challenging, especially if there is a US person involved.

 

[OCT2023]

US Citizen is headache for banking.
Do either of you reside in the US?

No, we live outside of the US

If, after careful research and advisory from qualified professionals, your shortlist is Samoa, BVI, Marshall Islands, and Seychelles, I'd go with BVI.

Make sure that your chosen service provider is licensed in BVI or, lacking that, a reputable service provider.

Banking and taxes are going to be challenging, especially if there is a US person involved.

Understood, would it be better to register the company 100% in my wife's name? I was going 50/50 based on this snippet.

 

[SCI]

If She is not a US citizen then put it in her name. She pays you a salary which you declare.

 

[FDS ADS]

Looking to open an offshore corporation in a zero-tax country remotely.

Found a service that recommends Samoa, BVI, Marshall Islands or Seychelles.

I plan to go 50/50 with my Non-US wife in order for the company to not be subject to US Taxation.

The service also offers to help apply for remote banking in Belize, BVI, Hong Kong, Mauritius, Singapore and Switzerland.

This would be a professional services business with international deposits and withdrawls along with Debit/ATM usage. No Merchant Services are used.

Do any of the countries and bank locations sound feasible for a US Citizen / Non-US Spouse planning to live outside of the US?

Thanks much!

U.S. is extremally hard to arrange, even if you go low tax jurisdiction (lower then 19%) then you need to pay GILTI and here applies other obligations.

 

[Don]

U.S. is extremally hard to arrange, even if you go low tax jurisdiction (lower then 19%) then you need to pay GILTI and here applies other obligations.

Estonia could be a great choice.
EMI accounts are very easy to setup.
Its not a zero tax jurisdiction, but you could setup a zero tax structure.

It may afford U.S. taxpayers a unique opportunity to avoid immediate taxation under both the Subpart F income and GILTI rules, without paying any current foreign tax.

Looking for a GILTI-Free Structure? Try Estonia | JD Supra

Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society...

www.jdsupra.com

 

[FDS ADS]

Estonia could be a great choice.
EMI accounts are very easy to setup.
Its not a zero tax jurisdiction, but you could setup a zero tax structure.

It may afford U.S. taxpayers a unique opportunity to avoid immediate taxation under both the Subpart F income and GILTI rules, without paying any current foreign tax.

Looking for a GILTI-Free Structure? Try Estonia | JD Supra

Estonia, the small Baltic country of just 1.3 million people situated halfway between Sweden and Russia, was named “the most advanced digital society...

www.jdsupra.com

We can say in idea it is correct direction. But arrangement needs particular investigation of case.

 

[Don]

We can say in idea it is correct direction. But arrangement needs particular investigation of case.

Yes, OP provided almost no information.
Newsflash: Banks dont treat clients equally.
Someone who can park USD 50M on an account for wealth management will have very different experience than someone with high risk business generating 500k yearly turnover.

 

[FDS ADS]

Simply, based on business activity and place of residence of U.S. individual can run tax planning process, since we do not have exact explanation of situation I would love to mention Act 20 and Act 22 of Puerto Rico which is one of the solution to run away from taxes legally.

Looking to open an offshore corporation in a zero-tax country remotely.

Found a service that recommends Samoa, BVI, Marshall Islands or Seychelles.

I plan to go 50/50 with my Non-US wife in order for the company to not be subject to US Taxation.

The service also offers to help apply for remote banking in Belize, BVI, Hong Kong, Mauritius, Singapore and Switzerland.

This would be a professional services business with international deposits and withdrawls along with Debit/ATM usage. No Merchant Services are used.

Do any of the countries and bank locations sound feasible for a US Citizen / Non-US Spouse planning to live outside of the US?

Thanks much!

Can you say nationality of your spouse, you country of residence, and your connection to U.S. including the days you spend in U.S. as well as your planned business activity.

 

[OCT2023]

AFAIK There is no GILTI tax unless the company is majority owned by US Citizen(s). That's why I had proposed the 50/50 offshore company formation (details in my first response).

Spouse is European, we both live in South America. I cannot spend more than 1 month in the US (I don't anyway) for FEIE purposes. Business is IT Services (no products, no merchant account, B2B wire transfers only).

If banking is the biggest obstacle, then what SCI posted (100% in her name) would be viable. But if banking is possible, would prefer the 50/50.

 

[daniels27]

Seems your turnover is low. Have you looked into Singapore? I think you will have much better chances. It will probably cost you just a little bit more than BVI. Also I would consider doing 100% your spouse when you open the company and then change it once the bank accounts are open.

Anybody knows a reputable service provider for Singapore that does not overcharge?

 

[FDS ADS]

AFAIK There is no GILTI tax unless the company is majority owned by US Citizen(s). That's why I had proposed the 50/50 offshore company formation (details in my first response).

Spouse is European, we both live in South America. I cannot spend more than 1 month in the US (I don't anyway) for FEIE purposes. Business is IT Services (no products, no merchant account, B2B wire transfers only).

If banking is the biggest obstacle, then what SCI posted (100% in her name) would be viable. But if banking is possible, would prefer the 50/50.

You can go to Hong Kong.

AFAIK There is no GILTI tax unless the company is majority owned by US Citizen(s). That's why I had proposed the 50/50 offshore company formation (details in my first response).

Spouse is European, we both live in South America. I cannot spend more than 1 month in the US (I don't anyway) for FEIE purposes. Business is IT Services (no products, no merchant account, B2B wire transfers only).

If banking is the biggest obstacle, then what SCI posted (100% in her name) would be viable. But if banking is possible, would prefer the 50/50.

But you need proper structure.

 

[daniels27]

You can go to Hong Kong.

Why Hong Kong? They have audit and the tax exemption is only available one year later if even. Isn't Singapore currently the place to go?

 

[FDS ADS]

Why Hong Kong? They have audit and the tax exemption is only available one year later if even. Isn't Singapore currently the place to go?

Here is an audit requirement, but the jurisdiction is prestigious, and taxes for foreign-earned income are 0% (There is no derogation that the exemption is only one year). Singapore and Hong Kong are more or less the same with reputation but in Singapore, you need to have a resident director and audit costs much more.

 

[daniels27]

The FSIE exemption is only one year???

As far as I know Singapore has no audit below 10M SGD turnover, while Hong Kong is very costly from 1 HKD turnover for the audit, especially if you have many transactions.

Also, as far as I know yes, you can do offshore in Hong Kong, but you need to apply after the end of the tax year to get the exemption. In Singapore, offshore is much easier, you just cannot transact with Singapore entities tax-free. (I am not talking about HK FSIE which covers dividends etc. only, but not trading income which normally is taxed unless you file for an exemption after the year).

 

[OCT2023]

You can go to Hong Kong.


But you need proper structure.

Hong Kong can be opened remotely?

 

[FDS ADS]

Hong Kong can be opened remotely?

Yes

 

[OCT2023]

Yes

I'm still researching this, but in my research came across something interesting. My wife is Italian, and therefore qualifies for the Panama-Italy Treaty which means she can receive Permanent Residency and an E-Cedula from Panama for opening a company and bank account in Panama without the need to reside in Panama. Additionally, she can qualify for Citizenship after holding the E-Cedula for 5 years (without residing in Panama). I know that Panama is a Territorial Tax Country, so effectively all Foreign-Sourced Income would be Tax-Free. I'm guessing this could be similar to Hong Kong but with the added benefit of the Permanent Residency and possible Citizenship after 5 years.

I'm not as familiar with Panamanian Banking, but the bank account would be for paying employees (my wife and myself) and paying into other foreign accounts (investments).

If you don't mind, could you give your initial thoughts?

Procedures and visas for Panama | Studio Panama Italia

At Studio Panama Italia, we are here to help you during every stage of your internationalization and structuring plans

studiopanamaitalia.com

 

[daniels27]

I'm still researching this, but in my research came across something interesting. My wife is Italian, and therefore qualifies for the Panama-Italy Treaty which means she can receive Permanent Residency and an E-Cedula from Panama for opening a company and bank account in Panama without the need to reside in Panama. Additionally, she can qualify for Citizenship after holding the E-Cedula for 5 years (without residing in Panama). I know that Panama is a Territorial Tax Country, so effectively all Foreign-Sourced Income would be Tax-Free. I'm guessing this could be similar to Hong Kong but with the added benefit of the Permanent Residency and possible Citizenship after 5 years.

I'm not as familiar with Panamanian Banking, but the bank account would be for paying employees (my wife and myself) and paying into other foreign accounts (investments).

If you don't mind, could you give your initial thoughts?

Procedures and visas for Panama | Studio Panama Italia

At Studio Panama Italia, we are here to help you during every stage of your internationalization and structuring plans

studiopanamaitalia.com

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There are a good dozen of such visa in Panama. As far s as I am informed, the part with the citizenship only works on theory. Many people never get it at all. Check the internet.