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by DrJokepu 722 days ago
That’s called a Controlled Foreign Corporation and it won’t work, because its earnings & profits need to be included on the Subpart F income of the shareholders.

Uncle Sam will get his share. Unless you’re a large corporation, that is.

2 comments

How is the large corporation structured that lets it work?
Controlled Foreign Corporation: a non-resident company, fund, institution or other entity in a low-tax country that is at least 50% owned or controlled, directly or indirectly, by resident taxpayers.
Because you have to put actual substance in the entity. If OP ditched his US citizenship, moved to the Caymans, and then started consulting for international clients - it would work.
Or unless you're extremely wealthy. The rich often pay 0-not much% tax no matter where they are in the world.