Recent content by Speedrunner

Hey. Please DM wrt to opening a Cyprus company. Thank you.

Hey. Please DM wrt to opening a Cyprus company. Thank you.

Thank you. I'm curious why Liechtenstein isn't brought up more often in these discussions regarding NHR and tax planning. What does Cyprus for example have that Liechtenstein doesn't? The CIT and dividend tax are the same, Liechtenstein has supposedly good banks and also other vehicles to...

I was always more of a Scorpion person myself. In your opinion, where does a Cypriot entity instead of a US SMLLC fit into your risk tolerance curve?

I see, thank you. I've got a follow-up question regarding the US LLC. Essentially the US LLC-NHR structure is not very compliant due to substance and PE issues. The iffy ruling on top of which this structure lies states that US deems the LLC transparent for tax purposes while PT deems it...

Under case 2360/2016 (the famous ruling), the income was classified as "rendimentos de capitais", meaning "investment income". Would that require social security payments?

Wouldn't the running costs of such a complex structure be so high as to render the structure ineffective unless you're literally making 7 figs annually? Also, how does social security payments in PT tie into the mix?

Keep us posted, if you can and willing

What else is on your list?

So how do you manage with having foreign (US?) owned LLC + NHR? I'm curious if you experienced any problems around "permanent establishment" or substance

If you were looking to be as close to fully compliant as possible, while optimizing for as reduced of a tax burden as SWIM could possibly wish for under the NHR, how would you go about this if you were to receive 6 figures EUR in salary and bonuses every year?

Where are you on the stance that salary can be received in crypto assets, such as stablecoins, and then held for >365 days to then be sold to fiat under long term capital gains? (0% tax)

Sorry to only circle back to this just now. Why would it be considered tax evasion? Wouldn't it fall under tax optimization? I've also heard about a setup similar to this: The Tax treatment of US LLCs in Portugal Under NHR and a similar setup, this would be considered foreign-sourced income and...

Hey there, SWIM is a Portuguese tax resident under the NHR scheme and lives in Portugal for at least 6 months a year. SWIM is doing independent advisory work for companies outside of Portugal to the tune of 6 figures USD per year. How viable is it for SWIM to set up an entity such as Delaware...