Why do you want to set up as Non-US LLP? Your dividends will be withheld at 15% for countries having treaties with the US and 30% for countries without treaties. Setting up a US entity in a tax free state on the other hand is probably more beneficial as your dividends will not be withheld and your US entity may enjoy lower tax bracket if set up properly. US Market offers myriads of investment opportunities and therefore it makes more sense to set up US entity. I assume that’s why you are using IBKR. Investing in Europe through IBKR for European is not a good solution as their European dividends will be withheld and treated as non European. https://www.thinkadvisor.com/2021/1...kota-really-worth-it/?slreturn=20211118075609 https://www.theguardian.com/world/2...y-the-super-rich-love-south-dakota-trust-laws
there are a million things a rich non-US person can do to reduce and defer their tax burden. US based entities and persons can’t do them.
Like? I am pretty sure those loopholes are closed now and WHT is applied across the board but could be wrong of course
I don’t think it’s a loophole but I don’t know a lot about it. but I know that as a US citizen I pay 24percent or 40percent tax on dividends depending on the treatment. I would love to pay 15percent that is likely credited towards any other taxes you would owe on that income. for the notional you are looking at, you really need to talk to a private banker.
Yes the 15% is sweet but you can find from the Deloitte global taxation review that it applies only to a select high tax location. You end up paying the full monty
again, I would ignore all the advice on here. None of us are in the same boat are you (either geographically or financially).
Firstly private bankers are out there to milk money out of you. They dont care on your tax situation; they’ll simply tell you to consult your own tax consultant. They could care less whether your portfolio makes money. They will sell funds/investments/insurance that will lend them the highest commissions. They are not keen if you buy individual stocks as they earn minimal commissions. Investing through IBKR will be a better investment decision than becoming private banking clients. Ever heard that Warren Buffett pays a lot less taxes than his secretary? He’s been postponing paying taxes by sticking to his investments for a long time. Long term holding also will net you qualified dividend which are tax less than ordinary income.
I spoke to one last week who specifically talked about structures to corcumcent inheritance laws in Indonesia - which I’m sure are of great concern to you and your vast fortune.