soloadventurer

If you are making incorporating decisions based on taxes, you should probably not incorporate. How will you address CFC rules in your home country?

Under Russian tax law, a company is a tax resident in Russia if (a) it is incorporated in Russia, (b) its management and central control are in Russia, or (c) if a treaty deems it to be in Russia. Estonia has no tax treaty with Russia, so (c) is not relevant. In your case, (a) is also not relevant. Point (b) is more interesting: do you live in Russia and exercise management of your Estonian company in Russia?

If yes, then you own a Russian-resident company and Russian corporate tax law is applicable. You are required to prepare financial statements and file corporate tax returns in Russia. Presumably there's also many foreign ownership disclosure requirements.

Please consider discussing your case with a tax advisor if you have not already done so. I would never ever easily recommend a citizen of an OECD country incorporate a company overseas without first thoroughly researching disclosure requirements and tax law. Please be careful as tax laws generally are of the "go straight to jail" type.

I wish this Estonian e-residency program would contain more warnings in red about the significant impact such a foreign company will have on a shareholder. This applies to Atlas as well--non-US-residents need to be extremely careful with US corporations as there's a good chance they will not actually be resident in the US.

In many OECD countries, if you, a resident of a state, incorporates a company in another state, and you control that company from your home country, your company in the foreign jurisdiction will be deemed a resident in your home country and require tax returns in your home country. I am perplexed by the number of people setting up businesses outside their country, not realizing the numerous disclosures and extremely complicated tax planning that comes with it.

Coinbase is a UK company. To take them to small claims court, you will need to file in the UK.

Interestingly, Coinbase UK Ltd. has no share capital and the 2015 financial statements show a going concern. [1]

[1] https://beta.companieshouse.gov.uk/company/09083955/filing-h...

EDIT: I just realized connecting from outside the US shows a contract between Coinbase UK, whereas when using a VPN from the US shows Coinbase Inc. So please disregard.

0/10 here, on Cellcard in Cambodia. No IPv6 address detected, but the DNS server appears to have IPv6 internet access.

2 double shot espressos, one early morning, and one late morning. No coffee after noon.

1 glass of watered red wine with dinner (my only meal each day). When going out, I will have 2-3 glasses of wine, but only once every two weeks or so. The rest of the time I'll drink Perrier or soda water.

3-4 glasses of water a day. More on workout days, but I find on a ketogenic diet my water requirements are less. I don't add salt to my food, and I cook all my meals. I don't use condiments either.

I don't drink tea, energy drinks, juice, smoothies, or pop. What I enumerated above is what I drink.

My meal plan is very simple. I follow zerocarb (meat and eggs only, no vegetation of any kind) and eat once a day only. Meals are always 3 or 4 eggs with 1 kg of steak, lamb, goat, or duck. I only drink water or Perrier. And before you ask, no, I do not get bored with a rare ribeye and eggs 4 nights a week.

I realize this approach is "out there" for most people, but over the last year it has produced great results in reaching my body fat percentage goal and increasing my lifts (Greyskull LP). I have no sugar cravings, no glucose crashes, and no hunger during the day.

It was difficult on two fronts: weaning myself off a carb rich diet, and then switching to 2 meals a day, and eventually 1 meal a day.

To be clear, I'm not recommending anyone switch to intermittent fasting or zerocarb without reading the rationale and critique of those two approaches. I have spent considerable time reading and experimenting over several years, and this is where I ended. I have put my parents on the same regime, and in the last six months their health considerably improved. They miss fruit, but my father is near diabetic and cannot tolerate any sugar, even "natural" sugars from fruit.

And contrary to popular belief, fiber is not required if you eat meat only. It is probably recommended if you eat vegetables, but I have consumed pretty much zero fiber for almost a year now and it works fine. Once again, don't take my word, but rather read the origins of why fiber is considered important, and then a critique of that assessment.

I use LinkedIn. I'm not a tech guy and work in tax. Whenever I meet clients, I add them on LinkedIn and leverage that to find more introductions. I know LinkedIn isn't well liked in the tech space, but for global businesses doing infrastructure development, it works exceedingly well.

For relationship management, I try to meet at least 6 clients face-to-face every week.

Can you clarify the meaning of "operate?" Do you mean operate or is being managed?

If you mean "operate," then there isn't really much to add. If you are performing some sort of SaaS (like Netflix), the US company will pay tax on worldwide profits. The other jurisdiction may assess a withholding tax, but in practice it is difficult to collect it from consumers. If you have people selling things in another country and concluding contracts, you may have a permanent establishment in that other country and be required to file branch financial statements and pay tax thereon.

If you mean "managed from a second country," things get more complex. If the "mind and management" of the company is in another country, that country will probably take a position that the US company is subject to the local tax laws. For example, if you are a Canadian that owns a US company or corporation and you control it from Canada, then Canada will deem that company or corporation to be a tax resident and you must file a Canadian corporate tax return in addition to all your US filings. You will need to look at the US-Canada Tax Treaty carefully to see how this plays out. In particular, the tie-breaker rules and anti-avoidance rules.

I'm a tax practitioner. I shudder when I see how many people are opening US companies without looking at their home country rules. Before you consider opening a US company, ask yourself:

(1) What is my foreign affiliate disclosure requirements?

(2) Will my US company be liable for tax in my home country? Will my US company be a tax resident in my home country?

(3) What are the residency rules and tie-breakers under my country's tax treaty with the United States? (If you don't have a treaty, it should light up as a red flag.)

(4) Do I have a budget to pay for local tax advice and compliance, and US tax advice and compliance, each year?

Tax is not simple!

I cannot upvote you enough. Juicing gives you the ability to easily consume a cup of flavored sugar water. Now throw in all the "healthy" raw kale and spinach and some seeds, and you end up with a concoction that is high in sugar, high in fructose, high on phytates, and high in oxalates.

There are reasons why our ancestors soaked, fermented, and sprouted various vegetation--to reduce the toxicity associated with consuming it raw and untreated.

Have you considered a zerocarb diet? It may help with the allergies, though if you follow zerocarb then it wouldn't matter as it excludes wheat and soy. I essentially eat nothing but meat, cheese, and eggs. If this sounds outrageous and impossible, come join us on /r/zerocarb and read the science and testimonials.

I did not make this choice lightly. For several weeks and months I got hung up on the "but you need vegetables and fiber" argument. I read and thoroughly did my research over a period of many months. My parents and I have tried many of the popular fad diets out there, including raw vegan where we would make "healthy" smoothies out of kale/spinach and some fruits (never mind that raw spinach is rather toxic with oxalates and other anti-nutrients, and the sugar content (especially fructose) from the fruits will lead us towards diabetes).

My parents are now so pre-diabetic that they cannot eat fruit anymore. A simple serving of pineapple will push my father's blood pressure over 200. Two servings and he will black out. Waking glucose level is about a 100 for both of my parents.

Then, we switched to paleo, and a few months later to zerocarb. It has now been several months eating nothing but meat, eggs, and cheese, and the results were night-and-day different to the raw vegan diet high in carbs and sugar. Now, we are keto adapted. Insulin sensitivity is slowly returning to normal. Waking glucose is improving for them (mine is normal). Lipid panels are improving. We all lost excess weight as well.

By following zerocarb, you automatically eat a FODMAP diet. You don't damage your intestines anymore from all that bulky high-fiber diets. You really don't need fiber--I have not eaten any fiber in months.

In the end, I experimented, my parents experimented, and we settled on zerocarb. There's an excellent book on this called the Fat of the Land by Vilhjalmur Stefansson. Read it with a bag of salt, but perhaps try a 60 day experiment.

I agree. I follow a stricter eating window of 23/1 where I eat all my calories in about 1 hour. The benefit of keto is you do not have sugar crashes, and if you are careful with caffeine you can eliminate those crashes as well. A constant supply of energy is wonderful. I also lift weight at the end of the fasting window, before I eat, and have not experienced any issues. I have been keto for a few years though, so I'm very keto adapted. My carb intake is less than 5g per day (I don't eat plants).

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I don't understand your question. Do you mean why didn't you decide to incorporate in the United States?

I'm not American, and I don't want anything to do with American taxes. That rules out any US LLC or corporation. My market is also Asia and the Middle East, so I opted for a Hong Kong company. No resident director requirement, and no tax on profits earned outside Hong Kong. There's no tax on salaries if earned outside Hong Kong, which leaves you with personal income tax in the country you're resident in.

Creating a Hong Kong company took about 1-2 days. I went to Hong Kong for a weekend to open a bank account. KYC rules require you appear in front of a bank officer to open a bank account.

You can consider Singapore as well, but Singapore has a resident director requirement.

What is your market, and where are you trying to sell?

KYC rules require you appear in front of the bank officer to open a bank account. If you are going to spend money on opening a company, and are prepared to pay the annual maintenance costs going along with financial statements, tax returns, and other reporting, you should be prepared to travel somewhere and open a bank account. Running a company is NOT cheap.

Where are you from? Have you answered the following questions?

a) What is my foreign affiliate reporting requirements? For a Canadian, you must file a T1134 annually. The T1134 for a controlled foreign affiliate (where you exercise control) is very onerous. It is not that bad for a non-controlled foreign affiliate.

b) What is my foreign affiliate taxation requirements, in that foreign jurisdiction? This is an answer that must come from Atlas I guess. But for a foreigner owning a US LLC, where the US LLC will be controlled from a country with which the US has a tax treaty, we get into many complexities.

c) Will I have an income pickup from active business income from owning a foreign affiliate? For Canada, this is a "no."

d) Will I have an income pickup from passive income earned in a foreign affiliate? For Canada, this is a "yes." Canadians should never earn rental income, royalty income, or other such passive income in a US LLC, for example.

e) How will I deal with the "place of central management and control?" Many countries deem a corporation to be resident in that country if you habitually exercise management and control from that country. For example, a Canadian that owns a US LLC will result in the following:

- US LLC is a tax resident of the US by virtue of incorporation, and must file a tax return to report earnings from the USA (no flow through). As the LLC will be a resident of Canada as well (see below), branch profits tax of 30% may apply (IRS 884).

- US LLC is a tax resident of Canada by virtue of being controlled, "mind and management," from Canada by a Canadian, and must therefore file a Canadian corporate tax return.

The situation is different for Canadians owning "C" corporations. However, it brings its own complexities and nuances. The reporting requirements are challenging.

For those seeking to own a foreign company, research your own reporting and disclosure requirements carefully.

Have you considered http://startupr.com?

I am not affiliated with them, but are using them currently and they are providing great service.

In Vietnam, Uber required a credit card for the longest time. This is a silly position to take, given most Vietnamese do not have credit cards. You can now use Uber without a credit card, but Uber's position had a cost.

Grab Taxi has now taken much of the market and do not require a credit card. I will never use a hailing service requiring a credit card, and as such I can never be charged a cancellation fee.

I'm always very fascinated by people's rationale and I enjoy reading these threads. Thank you for posting. My own journey took me in the opposite direction: I eat nothing but meat and other animal-derived products such as cheese and eggs (but not milk). I have made this decision after reading The Fat of the Land by Vilhjalmur Stefansson [1] and Why We Get Fat by Gary Taubes [2]. I consciously decided the most important dietary principle, for me, is to never trigger a strong insulin response. I have been zero carb (and therefore zero fiber) for about a year now.

I have since then thrown in intermittent fasting as well. I fast 22 hours a day, work out at the end of the day, and then go home and eat 1kg of steak/lamb. I think intermittent fasting is worth adding to any diet, vegan or otherwise.

[1] Book was printed in 1956, so copyright may have expired. There's PDFs online. Here's a link to Stefansson's Wikipedia entry: https://en.wikipedia.org/wiki/Vilhjalmur_Stefansson

[2] Non-affiliate: https://www.amazon.com/Why-We-Get-Fat-About/dp/0307474259

Can we also say Founders that can't sell are hobbyists? I can't code. But I work in industry (not tech related at all) and we have niche problems to be solved and customers are lining up. As of right now, I'm a solo "founder" with no coding skills and hired tech guys to do the MVP.

I think your original assertion is a bit much. I wish I was better at coding, but at this point in my life it is more valuable for me to sit with my clients and build relationships. I think that even if I was a very capable programmer, I would still not code and rather go out and talk to my clients or potential clients, because that is something my programming team cannot do. The more I interact with my clients, the more I learn about problems and issues they have that can be fixed with technology.

I think it greatly depends on your goal. If you want to raise capital, you probably need a US company.

If you are not American and your country does not impose onerous foreign affiliate reporting schemes, I can suggest Hong Kong. It is quick and easy to set up, is a relatively "clean" jurisdiction, and Hong Kong does not tax revenue earned outside Hong Kong. Hong Kong also does not tax employment income earned outside Hong Kong if the employee does not live in Hong Kong. If you draw money from the company, you will need to review your local tax rules.

Singapore is a good jurisdiction, other than the local director requirement.

I can write a fair bit more, but without knowing where you are from and what your specific needs are, it is difficult to provide useful feedback. Disclosure and tax rules vary significantly worldwide.

I'm a CPA. We love to engage on a contingent fee basis where we collect a percentage of credits approved. I once had a client that agreed to it, and we ended up collecting hundreds of thousands in fees for a few hours of work. They did not sign the same engagement the subsequent year, but insisted on time incurred.

If I was you, I would insist on time-incurred and refuse contingent fee. Ask them for their standard charge-out rates, insist on a minimum 20% discount on those rates, and ask them to provide you with a estimated time budget. They won't like it, but they'll accept the engagement because they will still make money. If they don't accept, then choose a different service provider.

I will not speak of the business case associated with using Stripe Atlas.

There are some tax considerations. It is not generally a good idea for Canadians to own US LLCs unless you know exactly what you're doing and why you are doing so. The below analysis assumes "C" status, as "S" status is not permitted for non-US person unit-holders.

In the United States, US LLCs are generally disregarded entities and profits will be taxed in the hands of the unit-holders. From a US perspective, a non-resident will thus receive the flow-through earnings from the US LLC and be required to pay tax as a non-resident individual to the IRS. Note: You'll be required to register the LLC and yourself with the IRS.

Canadian law does not recognize flow-through entities except in the case of partnerships and certain trusts. The US LLC, therefore, will be considered a non-resident corporation and the proceeds (the flow through income) will be treated as a foreign dividend in Canada. You will pay Canadian personal income tax on that.

Because the IRS tax profits in the year incurred, and Canada will tax in the year distributed, frequently you will be unable to utilize a foreign tax credit in Canada for the taxes paid in the United States. Historically, there was also the issue with the tax credit being in the name of the corporate LLC, and as it does not match your personal name, it cannot be utilized, but if I remember correctly the latest Protocol may have addressed that.

The above deals with the general aspects of taxation in the US and Canada. There's another important point and that is permanent establishment. The US LLC will have a permanent establishment in Canada if you run and manage the LLC from Canada. Canada's CRA will require the US LLC to submit a corporate tax return in Canada as well and pay branch tax of 25% on profits (reduced to 5% under the US-CA tax treaty).

A few other issues:

- Interest in foreign companies require form T1134 - Information Return Relating To Controlled and Not-Controlled Foreign Affiliates [1] be filed each year with the CRA. This tax form summarizes the balance sheet and income statement and associated tax treatment in the foreign jurisdictions. It is painful.

- If you have a bank account with over CAD 100,000 in cash, you must also file form T1135 Foreign Income Verification Statement [2].

- You will not have access to the Canadian Small Business Deduction as the US LLC is not considered a CCPC (Canadian-Controlled Private Corporation).

- You will not have access to the $750,000 lifetime Capital Gains Deduction on the sale of your business. (On a related note, sale of a LLC will require tax filings in both countries.)

- You will not have access to a dividend tax credit on dividends received from the corporation. (Although, the combined tax paid in Canada in either situation may be similar--some Excel magic is required to see the tax loss under both scenarios.)

- There are many US IRS forms to be filed too, but I'm not going to itemize them here now.

In conclusion, US LLCs for Canadians are hideously complicated and require careful thought and consideration as it will trigger an avalanche of forms and filings and make the tax planning situation very difficult for your tax adviser.

My personal opinion is that Canadians should stick to numbered provincial or federal incorporation. The overall compliance burden will be much lower and I suspect you can have access to whatever US LLCs have access to with a bit of extra effort. A Canadian company can relatively easily get a US bank account and I would presume merchant-related services, though I have not done that myself.

Basis: I'm a Canadian international tax adviser.

[1] http://www.cra-arc.gc.ca/E/pbg/tf/t1134/README.html [2] http://www.cra-arc.gc.ca/E/pbg/tf/t1135/README.html