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Moving 6 figures from US LLC to EU

bsdc

bsdc

New member
Oct 7, 2024
3
1
3
26
USA
#1
Hi everyone,

I formed a US LLC in 2023 as an italian resident and citizen.
Never declared, never moved money to europe, and have both a Chase account (opened physically there) and a couple neobanks.
Only moved small sums to US LLC Wise and then to Personal EU wise.

Since 2024 i am effectively unemployed to the government.

I am looking to buy a house here, so i'd like to figure out how: either move money to Europe somehow (obviously paying taxes, but without busting the whole LLC ideally) or figure out a setup where i can use the money without moving (impossible i think)

Invoicing myself from an italian company seems extremely risky, buying crypto and cashing out perhaps?

Or just open a local business and have fresh money flow there instead of US?

I could get people i know IRL, family members and such, to open local companies if that could help.
Same option feasible in the US, and in 1 other non-EU country i won't disclose.

Any other idea?
 
#4
SCHLOSSFINANZ said:
just pay your taxes, sooner or later they will anyway find out. Currently FATCA changes are underway that forces US banks to report
Click to expand...
I get that and i don't mind paying, but realistically how would i go about that?
Distribute profits and pay dividend tax on that?
Or register LLC as resident and then? Accounting requirements in USA and Italy are vastly different, i don't know if i can provide receipts for all my transactions.
 
#14
ilke said:
His name is FATCA, the same as the system.

Where is the spelling mistake?
Click to expand...
Wait. What!

I think we mispelled it all the time here:
https://www.offshorecorptalk.com/search/1150723/?q=FACTA&o=date

I was under the impression that this bs acronym was FACTA to make it sound like fact. But in effect, we are talking about FATCAT. So, in short they IRS wanted to become a FATCAT and just missed the last t in the acronym. But they are broke, no matter how much they can collect.
 
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#15
bsdc said:
Hi everyone,

I formed a US LLC in 2023 as an italian resident and citizen.
Never declared, never moved money to europe, and have both a Chase account (opened physically there) and a couple neobanks.
Only moved small sums to US LLC Wise and then to Personal EU wise.
Click to expand...

Ok, legally you are liable to pay tax to Italy when you earn it in your US LLC, even if you just keep it there and dont send it anywhere. You may get away with it though, as despite clauses of bilateral reporting exist, in practice US banks and authorities dont report much to foreign countries.


bsdc said:
Since 2024 i am effectively unemployed to the government.

I am looking to buy a house here, so i'd like to figure out how: either move money to Europe somehow (obviously paying taxes, but without busting the whole LLC ideally)
Click to expand...

Why is it so obvious to pay tax on transferring funds from the US LLC to you personally, but not on the US LLC profits?

It's primarily the tax on personal income that is ridiculously high in Italy and in Europe in general, and that causes Europe to be a lot poorer than what it should be.

And to resolve the problem of not paying crazy taxes when receiving money from your US LLC, the only reasonable solution without taking legal risks is to stop being a tax resident in Italy. Just register in AIRE somewhere, have your habitual abode and close family outside Italy and stay away at least 183 days. Nobody ambitious, who wants to make a good career or who is starting/running a business should be a tax resident in a tax hell country anyway. (But it's fine to visit such countries.)

Italy actually recently made it easier to stop being an Italian tax resident, in that they removed business and economic interests in the domicile test, leaving just familial ties. Meaning you can for example have a house for investment purposes in Italy without being a tax resident there.
 
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#17
bsdc said:
Hi everyone,

I formed a US LLC in 2023 as an italian resident and citizen.
Never declared, never moved money to europe, and have both a Chase account (opened physically there) and a couple neobanks.
Only moved small sums to US LLC Wise and then to Personal EU wise.

Since 2024 i am effectively unemployed to the government.

I am looking to buy a house here, so i'd like to figure out how: either move money to Europe somehow (obviously paying taxes, but without busting the whole LLC ideally) or figure out a setup where i can use the money without moving (impossible i think)

Invoicing myself from an italian company seems extremely risky, buying crypto and cashing out perhaps?

Or just open a local business and have fresh money flow there instead of US?

I could get people i know IRL, family members and such, to open local companies if that could help.
Same option feasible in the US, and in 1 other non-EU country i won't disclose.

Any other idea?
Click to expand...
1) convert the crypto into stablecoins for keeping things simple
2) register a permanent establishment of the US company in Estonia
3) move the stablecoins so they are legally owned by the Estonian PE. The PE will open a crypto exchange account.
4) the PE is entitled to withdraw equal amount of assets in EUR equal to the previously contributed amounts to PE without tax. So if you exchange stablecoins for cash and then withdraw there is no tax. If there is some capital gains and you withdraw more then initially contributed you pay some tax, which can also be great for future SOF.

I think best would be to exchange to FIAT as a corporation and then lend to other holding entities for acquiring real estate.
If you don't have great SOF docs then better to avoid notaries, which is possible in some jurisdictions.

This is still a good setup, but looking ahead if you want privacy know that most western countries are soon implementing CARF(crypto asset reporting framework) so crypto exchanges will also start automatically reporting close to all transactions, unless you structure the entity as non reportable.
 
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#18
bsdc said:
I formed a US LLC in 2023 as an italian resident and citizen.
Never declared, never moved money to europe, and have both a Chase account (opened physically there) and a couple neobanks.
Only moved small sums to US LLC Wise and then to Personal EU wise.

Since 2024 i am effectively unemployed to the government.
Click to expand...

So your already a criminal now :confused:.

bsdc said:
Invoicing myself from an italian company seems extremely risky, buying crypto and cashing out perhaps?

Or just open a local business and have fresh money flow there instead of US?
Click to expand...

So now you want to launder the proceeds of crime doh948"".

bsdc said:
I am looking to buy a house here
Click to expand...

You will end up being on TV. You will be one of those people having their house raided by masked police while their luxury car is loaded onto a flat bed. All being filmed by a TV network while neighbors hold their hands over their mouths to stifle their shock.


bsdc said:
Any other idea?
Click to expand...

Your already in a bad spot. See if you can regularize your affairs is best option. Otherwise move abroad and come back in some years with your fortune.
 
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