hold on.
What if somebody gets a HNWI Georgian residency with georgian tax
certificate and does the work from outside georgia? (for example UAE).
Let's imagine another EU country is challenging your residence, based on Georgia-EU country treaty most probably a tie breaking rule will be a permanent home.
You can have an apartment rented in Georgia for 100usd/month so you have tax residence
certificate from GE and qualify also under the DTA. At that point the US LLC distribution will be considered as foreign income according to the georgian tax code.
Any comment is appreciated.