Where to get advice for offshore structure

[mgrond]

I am thinking about creating an offshore structure to do a few things:
- protect assets that I have acquired after my divorce from my ex wife, specifically ownership interest in a partnership Business that I helped to grow And will be given an ownership percentage in
- use the company for consulting revenue that I will earn when I move abroad In next year to minimize US taxes ( I am a UScitizen but plan to move to E.U. country at least part time starting next year and full time in the future)
- ideally have a company that hold revenue and pays me a percentage of the revenue now, and the rest later when I have a lower tax burden

I am new to the forum,but hoping to get advice on structure of company(ies) and locations well as the same for bank account. I would like a structure that I will not have to report on US taxes, ideally, as this would give US lawyers knowledge of these.

I would like advice here, but good advice may be a recommendation on a consultant who can give me reasonably-priced and reliable advice on these subjects.

 

[Sols]

Since you're a US citizen, you are taxable in the US on your worldwide income regardless of where you live. You can only avoid this by living in a country which has a tax treaty with the US and which has a higher tax rate than the US.

But there are steps you can take to reduce your tax burden.

Contact a local/US-based tax adviser with an international reach. You need someone who understands US tax deeply. The Big Four audit firms can do it but you can get the same advice from smaller firms like Grant Thornton, BDO, or even Vistra.

Or contact one local tax adviser and then any of the major offshore/international tax planning firms to handle that tax advisory separately. Gives you more options.

 

[Gediminas]

I am thinking about creating an offshore structure to do a few things:
- protect assets that I have acquired after my divorce from my ex wife, specifically ownership interest in a partnership Business that I helped to grow And will be given an ownership percentage in
- use the company for consulting revenue that I will earn when I move abroad In next year to minimize US taxes ( I am a UScitizen but plan to move to E.U. country at least part time starting next year and full time in the future)
- ideally have a company that hold revenue and pays me a percentage of the revenue now, and the rest later when I have a lower tax burden

I am new to the forum,but hoping to get advice on structure of company(ies) and locations well as the same for bank account. I would like a structure that I will not have to report on US taxes, ideally, as this would give US lawyers knowledge of these.

I would like advice here, but good advice may be a recommendation on a consultant who can give me reasonably-priced and reliable advice on these subjects.

Hey, feel free to email. My partner is a practicing lawyer who specializes in the international taxation and structuring.

 

[VanguardFortuna]

Ditching the US citizenship is going to be your best bet for tax reduction anyway...

 

[Frank N Stein]

When you renounce US citizenship, there's going to be a huge exit tax.

 

[JohnLocke]

When you renounce US citizenship, there's going to be a huge exit tax.

How is this tax calculated, do you have any public information about that from a trusted resource? I'm curious that's all.

 

[mgrond]

Thank you all for the advice. There are a few pieces to this:
1)I want the offshore company to hold ownership that I may receive in an LLC so that I don't get stuck with taxes on the value of my ownership distribution at this point as this won't generate any revenue until the company is sold. If I take ownership directly, then I would owe taxes immediately even though I receive no cash.
2)I did speak with a local CPA, and while he is not an expert on international options, he said the following: "If you do not take money out of the company immediately, then you would not be liable for taxes on that money immediately, but you would be liable for taxes on that money at a later date, when it was distributed to you later." I just want to make sure this is correct by talking to someone who has expertise in this area.
3)I don't want this company's assets tied to me in tax documentation so that my ex's lawyers can not go after them to get her more money - even though all of these assets were obtained after the marriage, divorce courts in CA will consider paper assets such as these in determining payments to the ex. In court, her lawyer claimed former stock options were worth hundreds of thousands of dollars in revenue even though they had no real value. And the family court was not sophisticated enough to really understand what this meant.

Fundamentally, I am not looking to totally avoid taxes (e.g. abandon US Citizenship), but rather 1)shelter assets, and 2)optimize tax by shifting income timing.

Again, if you have reference to someone knowledgeable who can discuss these issues for a reasonable cost, or point me to other resources available on these topics, please let me know

 

[Txaxandlxaxwxyxexr]

Thank you all for the advice. There are a few pieces to this:
1)I want the offshore company to hold ownership that I may receive in an LLC so that I don't get stuck with taxes on the value of my ownership distribution at this point as this won't generate any revenue until the company is sold. If I take ownership directly, then I would owe taxes immediately even though I receive no cash.
2)I did speak with a local CPA, and while he is not an expert on international options, he said the following: "If you do not take money out of the company immediately, then you would not be liable for taxes on that money immediately, but you would be liable for taxes on that money at a later date, when it was distributed to you later." I just want to make sure this is correct by talking to someone who has expertise in this area.
3)I don't want this company's assets tied to me in tax documentation so that my ex's lawyers can not go after them to get her more money - even though all of these assets were obtained after the marriage, divorce courts in CA will consider paper assets such as these in determining payments to the ex. In court, her lawyer claimed former stock options were worth hundreds of thousands of dollars in revenue even though they had no real value. And the family court was not sophisticated enough to really understand what this meant.

Fundamentally, I am not looking to totally avoid taxes (e.g. abandon US Citizenship), but rather 1)shelter assets, and 2)optimize tax by shifting income timing.

Again, if you have reference to someone knowledgeable who can discuss these issues for a reasonable cost, or point me to other resources available on these topics, please let me know

I feel for your situation. Divorce laws are disgracefully unfair and divorce lawyers will do anything to take more and more.

About the issue.

Your CPA appear not be taking into account the CFC (controlled foreign companies) regulations and specific regulations about transparency of assets.

In any case. First step would be to chose a country. If you are looking into Europe, Cyprus could be one of the first country to look further on, for both second residence and the incorporation.

Second step would be banking (some would actually chose another country in this case, not Cyprus), Georgia could be good for a couple of years (no later than 2023) then you should update your planning taking into account next years political and financial factor.

In theory is always possible an international seizure of accounts and stocks but the procedure is difficult and very costly, so a normal us attorney would have many difficulties to take the money for you in behalf of your ex even after a judge decision.

In order to avoid even the risk of losing money you could always convert the money in cryptocurrencies when you feel further risks.

Disclaimer: just my opinion that you need to check out with your advisors and this is for educational and informational purposes only.

 

[CaptK]

As a US citizen you are fucked... sorry if you dont like the language but I want to emphasise the issue you have.
You are legally supposed to declare as per the patriot act. You haven't
You have been through divorce proceedings and even if she is not entitled to a penny she will try and f**k you.
When you start to pay yourself a dividend or transfer equity you could be found. Then the question is why didn't you declare.

If you have not set up a structure yet and are looking for the safest jurisdictions the answer is none. You are an American!!
That passport is the noose around your neck.

2 options

Nominee company
In any of the favourable jurisdictions. You are an employee on a salary and declare it, Head of Finance , pay tax.
As CFO all the other expenses you want to enjoy will be sanctioned the the "CFO".

Crypto
Its belt and braces and approach and can be accessed anywhere in the world at anytime. Your wallet will never adhere to a court order and you wont have to worry about CRS,FACTA, IRS or any other organisation.
Complete protection from all

 

[mgrond]

@CaptK Love the honesty. Thank you!

I have not received any ownership yet, so nothing to declare (I think).

I am considering crypto for protecting assets, thank you. Could I put money in crypto, then start a nominee company as noted below, then put that money (or some of it) into that company's bank account. No tie to me, right? As I don't own the company?

But with the company, I like the idea of the nominee company. I can have that company receive the shares, and I can act as CFO and take no salary until a later time, after the company has sold and the shares actually generate cash or have a value. But as long as I leave the money in the company, I am not taxed, right?

Do you have a recommendation on a "safe" way and location to set up a solid nominee company. One that I can trust the money will not run off at some point...

 

[CaptK]

@CaptK Love the honesty. Thank you!

I have not received any ownership yet, so nothing to declare (I think).

I am considering crypto for protecting assets, thank you. Could I put money in crypto, then start a nominee company as noted below, then put that money (or some of it) into that company's bank account. No tie to me, right? As I don't own the company?

But with the company, I like the idea of the nominee company. I can have that company receive the shares, and I can act as CFO and take no salary until a later time, after the company has sold and the shares actually generate cash or have a value. But as long as I leave the money in the company, I am not taxed, right?

Do you have a recommendation on a "safe" way and location to set up a solid nominee company. One that I can trust the money will not run off at some point...

When your liberty and money are both at stake. Honesty is the only way to be.
No ownership now is good, gives you time to find the perfect fit.

Profits from Crypto into a nominee company will work. The advantage of crypto wallets is that they can be held by nominees but you are 100% protected if you change the seed phrase. You are an employee with a contract, perks and bonuses.

The company making a profit and keeping it in is ok so long as you are not shareholder.

I will emphasise take a salary and declare because it then links you officially. So its never a point of discussion in the event you are somehow linked. Whether it be as an employee or as a consultant.

PM me we can go through options