nevada llc corporation

International "Cloud Business" CFC Package - 100% U.S. tax deferred income (The "Google Plan")  
Your "Cloud Business" should not be "held hostage" to the highest corporate tax rates in the world. Apple does it, Google does it..... We have put together a package to free your business from taxation so you can watch it grow as an International Business Corporation (IBC).

A "Cloud Based" IBC can defer 100% of its profits from U.S. taxation: The basic requirements being that the server is located outside of the U.S. and that the IBC is managed by International Directors, rather than by the U.S. shareholders. Of course you will need offshore credit card processing, banking and more... our package includes all this and much more.

The U.S. has no taxing authority over a foreign corporation
The U.S. has no taxing authority over a foreign corporation that conducts no business in the U.S. So if, for example, the services are performed 100% "in the cloud" on a server located in the Isle of Man by a Hong Kong Corporation, then none of this activity is subject to U.S. taxation. In an attempt to assert control over foreign corporations, the U.S. has passed laws asserting control over U.S. shareholders of foreign corporations: As such a Hong Kong company owned by U.S. shareholders becomes a (U.S.) Controlled Foreign Corporation (CFC), and the U.S. shareholders have to comply with U.S. tax reporting requirements... HOWEVER....in the above example the Hong Kong company's earnings can be reported to the I.R.S. (by the U.S. shareholder) and NO TAX would be due. Only if the Hong Kong company actually pays out a dividend would any U.S. tax become due. Certainly there are ways to extract a portion of the earnings back to the U.S., but those funds that remain within the Hong Kong company as "retained earnings" are "100% U.S. tax deferred" to the U.S. shareholder. This is clearly an exciting tax strategy and exactly what Google, Apple and many more large corporations have been doing for years.

In a way your CFC becomes like an "Offshore IRA" where unlimited amounts of income can accumulate 100% tax deferred (Google recently reported to the IRS and the SEC that it has $30 Billion stashed overseas). Of course in the future, if the U.S. shareholder were to expatriate, then the foreign corporation would no longer be a "U.S. Foreign Controlled Corporation" and dividends could be paid to the shareholder free of U.S. tax. There also remains the possibility that the U.S. will "wise up" and allow U.S. shareholders to repatriate their offshore deferred earnings at substantially reduced tax rates (5-10%).

Bona-fide foreign business and "foreign source" income
In order to qualify for these "tax deferral benefits", the CFC must be operating a bona-fide foreign business. This means the CFC should be selling an automated (Cloud Based) service or selling a product (on a foreign server) on a regular and continuous basis and must be managed by Directors living outside of the U.S. The CFC may not have a U.S. office, or any U.S. agents working exclusively to market or sell its goods (as this will create a "permanent establishment"). The CFC may have shareholders who live in the United States, however the shareholders must be passive investors (having no control over the company’s day-to-day operations).

International taxation is VERY complicated and it is important to make sure that your business model generates "Foreign Source Income" and why our package is currently limited to "Cloud Based" business models. Other (more complex) situations where Foreign Corporations or U.S. shareholders may be required to pay U.S. income tax are described in U.S. Taxation of Foreign Corporations.

International Directors
We work with international service providers that provide the International Directors and CFC Management Team necessary to establish a bona-fide foreign business. Please note this service is complicated and in order to provide these services, an International Trust will need to hold the shares of the CFC. As a consequence the Bahamas International Asset Protection Trust Package will need to be purchased in conjunction with the CFC Package.

Management of (Tax Deferred) Retained Earnings
Once the company's profits have been retained "tax deferred", it would be prudent to start making offshore investments. PLEASE NOTE: These tax deferred earnings CANNOT be invested is U.S. assets (or they will become taxable). With our help, opening offshore brokerage accounts for your IBC (under your signature authority) will be a key step in the process of diversifying your assets outside the jurisdiction of the United States and a key step in protecting your assets. If you prefer NOT to have signature authority over these accounts, the Trustees of your Bahamas International Asset Protection Trust may manage these funds (increased trustee fees apply).

Do-it-yourself CFC?
As a U.S. person, you may of course structure a CFC business yourself (without our help) and we highly recommend that you do, however this is not for everyone as it would require you to move out of the United States, become a legal resident in a no-tax/low-tax country and to remain outside the U.S. for (on average) nine months a year.
 
Tax/FATCA Reporting for U.S. Persons with Offshore Trusts / Companies / Assets / Financial Accounts   

Offshore tax reporting has gotten complicated, but with the right help, it is really no more complicated than preparing a complex tax return for a U.S. corporation! The problem is that there are many corporate service providers, both offshore and onshore, that "hard sell" offshore entities to a client without any disclosure whatsoever of these reporting requirements.

We feel that the marketing of offshore entities to U.S. Persons without full disclosures of their tax reporting requirements is grossly unethical. In fact a simple disclosure is just not enough for us:  Not only will we advise and inform you of these I.R.S. Reporting Requirements prior to processing your order, but once you become a client, we will provide you with "cliff notes" to provide to your accountant and issue reminder notices in advance of the filing deadlines of the various forms.

 
International "Cloud Business" (CFC) Package PLUS the Bahamas Intl. Asset Protection Trust  
Your "Cloud Business" should not be "held hostage" in a "high tax" jurisdiction! The U.S. has one of the highest corporate tax rates in the world. Apple does it, Google does it..... it is easier now than ever to free your business and see it grow as an International Business Corporation (IBC). "Cloud Based" businesses (if structured properly) are able to defer 100% of their profits from U.S. taxation: The basic requirements being that the server is located outside of the U.S. and that the IBC is managed by International Directors, rather than by the U.S. shareholders.

Please note this service is complicated and in order to provide these services, an International Trust is required to hold the shares of the CFC. As a consequence the Bahamas International Asset Protection Trust Package will need to be purchased in conjunction with the CFC Package.

International "Cloud Business" (Hong Kong CFC) includes:
  • Certificate of Incorporation issued by Companies Registry
  • Hong Kong Official Registration Fees (includes BR)
  • Memorandum of Articles of Association - Preparation & Minutes
  • Provision of Hong Kong Registered Office (required by law)
  • Provision of Hong Kong Company Secretary (required by law)
  • Provision of an Individual Director (required by law)(provided by CFC Management Team)
  • Company Director (provided by CFC Management Team)
  • Nominee Shareholder (Shares held by the Trustee of the International Trust)
  • International Company Bank Account Opening ($500.00 value)
  • Basic Hong Kong Mail Receiving Service
  • Offshore Regulatory KYC Administration
  • I.R.S. reporting requirement notifications

Bahamas International Asset Protection Trust Package includes:

To learn more about the details of a Bahamas Irrevocable Discretionary Asset Protection Trust, please review the Bahamas International Trust page.


Total Combined Package Price: $6750.00
+ CFC Management Team (from $2000 monthly)
 - N.B. There is a strict eligibility screening requirement prior to client on boarding
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