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?

Hey all, I'm going to go live on youtube in a couple hours. Scheduled for 2:30 PM CST. You can see us live at youtube.com/jamesbakercpa Please come and bring your immigration questions! Sorry for the short notice I forgot to send this.

I have single member LLC that I plan to convert to multi-member by adding C-Corp that I've created so I could shift some income to it that I could then cancel with deductions allowed by US rules which are not allowed in my country. Would having US C-Corp as a partner cause any real risk of MMLLC being considered engaged in US trade or business? I'm doing consulting from abroad for US client, C-Corp has no assets/people in US and I would still be manager of the LLC. C-Corp's role would be to basically act as EoR and give me deductible fringe benefits. My understanding is that as long C-Corp has no people working on behalf of MMLLC on US soil partnership won't become ETBUS

I'll be on the zoom link happy to chat and answer any questions. See you there! Best James

Hello all, I'm live on the monthly meeting. I usually just have this for the VIP group but would welcome anyone here to join as well! Thanks for being a part of the community and hopefully we can connect over the next hour https://zoom.us/j/92323899634