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Digital Company Formation

Wyoming Non-Resident LLC

Tax Haven Jurisdictions

Synopsis:

Home of Yellowstone National Park - Located in the northwestern part of the Rocky Mountains. The first state in the union to introduce limited liability companies back in 1977 and still very popular with virtually all of the same benefits as Delaware save that the Certificate and Operating Agreement is not as flexible as those in Delaware.

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Tax Planning Credentials

Internal Investment in the USA:

Domestic LLC’s can prove to be very effective corporate vehicles, particularly for non- American nationals. The reason for this is that they allow for non-US citizens/green cardholders to benefit from ‘fiscal transparency’. In simple terms, this means that the profits of a domestic LLC can pass through the company and be distributed directly to the foreign owners preventing the possibility of double taxation. The corporate equivalent, known as sub-chapter S Corporations, do the same but can only be used by US citizens/green cardholders.

General LLC benefits

  • Wyoming is considered to be actively pro-business and is relatively free of bureaucracy.
  • The certificates of formation, articles of organization (if applicable) and the LLC agreements/operating agreements are all remarkably flexible
  • All legal documents supplied from the appropriate division of corporations are apostilled pursuant to the Hague Convention of 1961.
  • Highly respectable and credible jurisdictions.
  • New LLC’s can be registered in as little as 2-3 working days.
  • Well educated population.
  • Highly developed corporate and general law
  • Excellent communications.
  • Prestige of having a US registered entity.
  • Availability of efficient and cost-effective serviced office address facilities.
  • Low annual franchise taxes.
  • Fiscal transparency for both domestic and non-resident LLC’s.
  • Ability of non-resident LLC’S to be externally managed in low tax, tax-free or tax exempted jurisdictions

Double Taxation Treaty Network

The United States of America has undoubtedly the world’s most comprehensive and well-negotiated double taxation treaty network with treaties having been concluded with over 60 different countries. However, please note that such treaties can only be exploited by domestically managed and controlled companies subject to appropriate State and Federal taxes.

Non-Resident LLC’s:

These need not be taxed on their world-wide income — this being the position for all other American legal entities — provided both the certificate of formation and LLC agreement has been expertly drafted. In fact, provided the company conducts no direct or indirect business in the USA and neither the managers, nominees and/or beneficial owner(s) are US citizens or green card holders there should be no US tax consequences provided there is genuine external management and control.