[michaelschade]

Great question! I've learned a lot about this as I've gotten to hear from entrepreneurs that tried to setup in their own country, but ultimately came to the US. The video on our site gives some glimpse into the problems these entrepreneurs run into: https://stripe.com/atlas#stories

The gist is that certain countries have a better business and banking infrastructure than others for entrepreneurs looking to establish a global company. This isn't necessarily specific to the US—and we'll be expanding Atlas to more countries—but the US is a solid starting point, based on what many entrepreneurs in emerging markets already do.

For example, incorporating in a place like Delaware allows companies to issue stock to employees, makes it easy to raise money from global investors, and provides the stability of clear corporate rules and case law. (Most Fortune 500 companies are established in Delaware). Getting started with a US incorporation also makes many more services accessible to you, that might not be available if you incorporated in your own country with less support for new businesses.

It's a personal decision, for sure, but if you're in a country where you're finding your business constrained by the lack of particular banking infrastructure or access to business services, we think Atlas can help.

[flashm]

This only really works for people that aren't already setup as a company though.

You can't just open a new company in another country and expect to start moving your revenue to it, it just doesn't work like that. For instance, I'm registered in the UK and would have a tough time telling HMRC 'oh that's my US company, nothing to do with you'. It's a completely different problem if you already run a business and want to open a US branch. That's the same for pretty much anyone in the EU.

I think that needs to be made more clear in the schpiel.

[phillmv]

>You can't just open a new company in another country and expect to start moving your revenue to it, it just doesn't work like that.

It kind of does work like that? Granted, it depends on how you structure it.

I confess I'm not privy to how taxes work in the UK, and that further I'm not an accountant but: I too am responsible for a US and non US corp. You may have to declare your US corp as an asset in the UK, for all I know.

That said, if you have a US legal entity that is booking revenue then HMRC doesn't have any jurisdiction. That USCorp pays US corporate taxes just like any other.

If you move any of the US income to your UKCorp or your UK resident person then the Crown will happily takes its cut.

[chrisdew]

If you are resident in the UK and control a US company, HMRC need to be told about it. https://www.gov.uk/guidance/controlled-foreign-company-an-ov...

The US company will pay 20% UK Corporation Tax on (worldwide) profits and need to fill out CT600 each year.

You will probably be able to pay lower taxes in the US as a result of double taxation treaties, but it's going to be a very tedious task to organise.

[phillmv]

Aha, that's fair. Judging by the site it seems you'll have to take care to demonstrate that you're not shifting UK derived profits; but either way you'll want to chat up an accountant.

In my jurisdiction, to my knowledge and experience, they're considerably more lax.

[wfaler]

Nope, nope, nope.

If it was just about registering a company somewhere else and your home tax authorities had no jurisdiction, every company in the world, small or big would be incorporated in tax havens like the British Virgin Islands only.

If a company is controlled from the UK, you can bet your bottom dollar that the UK tax authorities have jurisdiction. Only a very small minority, mostly less well-developed countries allow you to incorporate elsewhere without having to pay tax and report where you are.

Corporate tax residence internationally tends not to be a matter of where a company is registered, but from where it is effectively controlled. This is a matter of fact, not a matter of paperwork, so you can't get around it by just appointing a buddy to sign papers who lives in the right country.

Not only that, incorporating elsewhere opens a world of complexity, pain and double taxation. A simple example: A US LLC with more than one owner is usually taxed as a partnership - eg, US tax is due at individual marginal rates. The UK on the other hand treats US LLCs as "opaque", which means they'd want to tax it as a corporation (there are legal cases to this fact). So a UK resident LLC owner could end up having to pay up to 39.6% tax in the US, then 20% AGAIN on the very same income in the UK, before having extracted a single cent from the company. Then if they extract money from it, there's an additional up to 38.1% dividend tax, for a whopping 90% marginal tax rate.

Now, double taxation treaties _may_ come to the rescue, but I wouldn't bet on it being without a fight through the courts to prove they apply.

[lstamour]

Yeah, LLCs don't appear to be the best method unless you can prove to the gov't how things were taxed (or not). That said, I'm not entirely sure things get that bad. First off, it's not a 90% rate, by those (worst case) numbers, it's a 70.08% rate. Still absolutely terrible, but... I'd take advantage of any advice you can find, both on local and US perspectives before committing to any course of action involving this product. Particularly looking forward to additional blog posts and resources on this, along with stories of best practices that are country-specific :)

[bgaluszka]

> oh that's my US company, nothing to do with you

Can you expand on this? I don't understand a problem here.

[flashm]

Check chrisdew's answer above. It just doesn't work like that in the UK, or most places in the EU. If it was a totally different company, doing a totally different type of business, then you could argue the case that it was nothing to do with it. You would still have to pay income tax on any money you remitted into the UK though from your US or other earnings abroad.

In much the same way as the US treasury want's a piece of US citizens worldwide earnings, I believe.

You really do not want to mess with HMRC in the UK. They will chew you up and spit you out without a care in the world if you don't play by the rules.

[reviseddamage]

Why SVB and not WF? Seems odd that the sponsor bank for your payfac distribution, that has more resources than SVB, won't equally house the account for this new vertical. Any particular reason?

[SkyMarshal]

Having used SVB at two startups now, they just get startups in a way that the big banks don't. They're not a huge multinational behemoth with its own corporate culture, but rather they specialize completely in the SV business/tech/startup world, it's their DNA. That little intangible is worth a lot.

https://en.wikipedia.org/wiki/Silicon_Valley_Bank

[reviseddamage]

That's anecdotal testimony really isn't it? and it's not true for fintech startups, SVB doesn't even bank Stripe's core payfac business. Other than the namesake, most fintech payment companies use WF, Fifth Third, Chase, Comerica or Cross-River.

[pbreit]

Atlas is not directed at fin-tech companies. SVB is more startup-friendly than WF.

[pbreit]

reviseddamage: You were questioning why Atlas went with SVB and noted that SVB doesn't bank fin-tech in general.

There's no reason Stripe's selection of a payfac provider should (strongly) influence it's selection of a corporate/startup banking bizdev partner. Atlas is linking companies up to regular corporate banking services.

[reviseddamage]

That is also not what I was implying. Banking shell companies is a very high risk activity frowned upon by the OCC as most of the time they are mismanaged. Only larger banks have the flexibility and the bandwidth, and the contingency to manage them. It would seem only likely the the bank that is already banking Stripe, would be the likely one to also bank the shell co's that would be processing through Stripe. Easier on the bank to have oversight and line of sight of the business activities. SVB on the other hand without having other oversight on Stripe, really no vested interest in Stripe's success, and much smaller bandwidth and risk management resources is the banking partner for the shell co's, that is strange, which is what I noted. It is not a normal and natural event, hence my original question.

[reviseddamage]

No one said that Atlas was directed at fintech.

[tammyp]

I'm curious about this as well. How did you choose your banking partner and what considerations did they have re: kyc/aml in this venture?

[iosifakos]

Are these first invites directed only to innovative startups, or web development agencies, with long term US customers, can apply now too?

[pbreit]

I still don't really understand if this is targeted at US businesses/citizens or non-US?