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Global Business Growth Club

1.9k members • Free

19 contributions to Global Business Growth Club
Puerto Rico LLC as US Estate Tax blocker
I've been looking into cheapest way to block US estate tax for non-residents and came across Puerto Rico LLC which is only slightly more expensive than US LLCs My findings: - It has PR corporate taxation by default but can elect pass-through (partnership-like) taxation even with single member (DE treatment status is only for PR-owned LLCs) - so if it's not engaged in trade or business in PR and doesn't have PR resident members it shouldn't be taxed in PR - Puerto Rico pass-through entity tax return instructions indicated that only entities engaged in trade or business in PR have to file that return and as far as I know there is no equivalent of form 5472/1120 - Under federal tax law PR LLC is foreign - IRC § 7701(a)(5) and corporation by default - Treas. Reg. § 301.7701-3(b)(2)(i)). - Changing tax status in PR doesn't change federal tax status causing hybrid entity mismatch - Stock in non-US corporation is not US situs asset under Treas. Reg. § 20.2105-1(f) I haven't been able to confirm not having to file PR tax return as it looks like this exemption only exists in instructions - https://hacienda.pr.gov/sites/default/files/documentos/inst_pass-through_entity_2022.pdf Anything I'm missing?
0 likes • 15d
Just looking at US estate taxes, which is horrid for a non resident who only gets a 60K allowance I've read, and stocks/bonds etc are classed as US 'property'. So for a foreigner investing into the usa this is a real thorn. I imagine not alot of people know this. Perhaps @James Baker could do a video on this topic?!
All engines running!
Thanks to the team at JBA, we are now fully operational and have launched our first artist lifestyle service catalog via our virtual call center. A steady level of excitement buzzes around the folks we now interact with. In a short span of time, we have gone from just building a bunch of IT systems to establishing an actual business. Thank you, James, Andres, Paola, Luis, and the superb team at JBA 🙌 If anyone in the community wants insight into the system decisions, process, and tips on IT cost optimizations or IT strategy, I am happy to take some DMs and calls to present a general overview of the system architecture that made things work for us. Glad to help where we can!
0 likes • 15d
what is an artist lifestyle service?
Residential Address
Having watched James' last video talking about banks getting awkward and wanting US residential addresses, I was wondering if anyone had used or considered using an RV Club address which are often used by american nomads and travellers?
Recent discoveries - Finally got all 3: Wise, Relay and Mercury, plus found good service
Been a while since my last post. With the climate getting stricter in regards to compliance for US bank account openings for Non-Residents I wanted to share my recent experience: I now managed to get: - Wise (most recently asked me to re-verify my personal address but not my business address) - Mercury (in good standing) - Relay (by far the hardest to get for me but it worked finally thanks to some new tactics that I came across, more on that below) Planning to get two more Non Fin-techs (likely WF and BOA), plus a personal US bank account, just to be all covered. I had struggled months getting all three accounts, especially in the beginning when I tried to do everything by myself. Also got semi-scammed by a Fiverr freelancer, but got my money back. My goal was to get all three because I wanted security / backup solutions in case one closed down or didn’t work. So far now my main business account is Mercury (as the operational account for my business), I make use of Relay as my business savings account and Wise for transfers (owner distributions) to my personal accounts abroad. I have Belgian, German, Swiss, Czech, Singaporean and Georgian (Multi-Currency) accounts now for personal. Most of them free. This setup works great for me. Mercury rejected me once first. I then tweaked my application and it worked. Relay was the toughest, requesting: - All documents Mercury requested plus special proof of address, plus lease agreement and a lot of back and forth. I had bought a great info-product (playbook and video course and other materials like EIN guide) from a consulting / tax advice niche business called TaxProteX. Was a pier’s recommendation. They basically give all info from start to finish on how to successfully set up a US LLC for foreigners. Not like an agency but much more like an information resource. Highly recommend them. They helped me with Relay in the end, also connecting me with a real address service. I also followed their EIN guide when I set up the LLC and got the EIN. Went pretty lucky for me with the bank accounts sum total, since that (address) was the biggest hurdle for me. After Mercury and Relay WISE was easy (provided them with my Relay and Mercury statements).
0 likes • May 3
I'd be very interested to know how you solved the business address issue...
Business Address Proof of Address (using an EIN letter from IRS?)
I was watching a video where JB was talking about proof of business address and that he uses sub-lease agreements for his clients. But given the business has to have the EIN in the same address, why couldn't the EIN letter from the IRS be uses to prove the business address? Anyone have any thoughts on this?
1-10 of 19
Brandon Smith
3
43points to level up
@brandon-smith-3871
Expanding on the journey ...

Active 13d ago
Joined Dec 13, 2024
UK
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