[jtheory]

Another possible avenue: if you can work as a private contractor (or remotely) for companies OUTSIDE of Denmark, you may be able to base your source of revenue in the US, pay US taxes only, and get a long-term visitor visa in Denmark.

Basically, you set up a business presence in the US (an address and a phone number.. which could be a paid virtual office service and a SkypeIn number... and stick with US bank accounts, file a D/B/A, etc.), then you simply work remotely, all the time.

From the Danish perspective -- my experience is in France, but I know other European countries have variations on the same theme -- basically you prove to them that you have sufficient money and external income to stay in Denmark, housing (your gf would sign an affidavit), health insurance, and they give you a visa for a year, which you can renew each year by proving the same thing over again.

In France you have to apply from outside the country, so if you have to get things set up in the US this would be the time to fly back there to get the process going.

Whatever you do, best of luck; my wife & I have worked our way through different immigration statuses in various countries, and it's always frustrating.

[flexie]

It probably wouldn't work. Denmark taxes residents on their world wide income, cf. the Danish Act on Taxation at the Source: https://www.retsinformation.dk/forms/r0710.aspx?id=134306 (Sorry, I can't find a translation)

Another question is whether he would be interested in avoiding Danish taxation.

If he chooses to incorporate in Denmark, the taxation is a flat 25 percent of the profits, and - which is just as important as the percentage - most expenses can be deducted when calculating the profits for tax purposes. I don't believe American corporate tax is lower.

If he doesn't incorporate, or if incorporates and pays out salary from his corporation to himself, he is taxed personally. The Danish income taxation is on a progressive scale, ranging from around 10 percent to around 60 percent but again with quite good possibilities for deductions. As a rule of thumb, most people end up paying little more than 40 percent of their total income, even if it exceeds USD 100,000. I don't think the combined federal tax, state tax in California and social security is much lower than that.

As an American citizen, the US would tax him on his world wide income although he is no longer resident in the US. But there are different possibilities for tax deductions such as the foreign earned income exclusion for the first USD 95,100 made abroad. Also, there is a double taxation treaty between the US and Denmark which may take care of any taxes exceeding the USD 95,100.

Anyways, he would have to talk to both a Danish and an American CPA about that. It would be very expensive. In my experience, tax planning is for large corporations, not for the rest of us.

[jtheory]

As I mentioned, I can't say anything about Denmark, but I spent 5 years with this setup in France.

In France during that time, I wasn't a resident (and not allowed to work for a French company, or get any benefits of residency); I was a long-stay visitor. It's a status designed for people who's lives, income, and often main residences, etc. are based elsewhere who just have a reason to stay in X country for more than the normal tourist visa (but they'll be going back someday, probably).

If he gets sponsored by a Danish company, he'll surely need to pay Danish taxes then. Though it's possible he'd get a discount; I know the Netherlands gives US immigrants (my brother among them) a significant tax reduction -- to US-similar rates -- to make immigration there more enticing.

If he does need to pay Danish taxes at some point, quite right, there's a treaty to avoid double-taxation -- whatever he pays in Danish taxes would be basically subtracted from what he owes in US taxes.

In France as a long-stay visitor, I was required to submit French tax returns (where I owed nothing, and it's pretty simple -- the middle-aged ladies in the tax office are really nice to me) and US tax returns (where I have a US accountant to help me out; he's not hugely expensive, actually, even though we have bank accounts in 3 countries and own residences in two; I think we paid about $1K last year).

Danish taxes are probably closer to the French system (fairly simple) than to the US system (horrendously complex unless you just have W-4 income), so he may never need a Danish accountant.

It would be nice if tax planning were just for large corporations, not individuals; unfortunately, depending on how interesting you make your life, sometimes it's unavoidable. :)