Setting up offshore trust with company structure for eventual move to US

I am surprised no one has answered your question yet. But why have you specifically chosen Cayman or BVI? You could set up a regular company in for example New Mexico, Wyoming, or Delaware and take advantage of the benefits there, especially since you are planning to move to the USA anyway.

SvenOrestis93 said:

Thank you. You mean via a “transparent” LLC?
This would bypass the need for the additional layer of company and probably make banking easier too I’d imagine?

Click to expand...

SvenOrestis93 said:

I’m currently a UK non-dom looking to move abroad temporarily and set up structure for an eventual move to the US (visa is not the issue).
I have a Cyprus trust where I’m excluded from benefit (alongside spouse etc, siblings are beneficiaries) and thinking of setting up an offshore company (cayman, BVI) with paid directors underneath it to move an actively brokerage account into the company (main source of wealth, no crypto). Cyprus companies are impossible to use as Interactive Brokers makes it very difficult and in any case it’s 12.5% not zero.

Ideally I would be an employee (active trader) of that (maybe BVI/Cayman) company and could take a salary (perhaps with an EOR in the US) to pay for things in the US while the gains compound tax free in the company - because the trust that owns it would count as a non-grantor trust given I and any spouse/kids are excluded from benefit.

This sounds like it would all work tax wise, but wanted to get this group of people to poke holes, since it all sounds way too easy in theory for it not to have issues

Click to expand...

Hey,

In your case, a company in Mauritius or Seychelles would be a great option, if you`re looking for a proper license offshore structure. If you`re going to open a default LLC you`ll struggle with a bank account. However, Saint Lucia can be a cheap offshore option that will cover basic trading activities.

SvenOrestis93 said:

Thank you for this!

Why is Mauritius or Seychelles better than BVI or Cayman, is it harder to bank those for LLCs? Could I also open a transparent LLC directly owned by the Cyprus Trust (or a Cyprus LTD company), or would that cause similar banking issues?

My other question really also sits around me being able to be employed and take a salary from such an LLC without it causing the non-grantor trust status of the Cyprus trust to cause tax issues for the underlying companies.

Thanks!

Click to expand...

Mauritius and Seychelles are great options because they're easier to bank with and have favorable tax environments. BVI and Cayman can be a bit trickier when it comes to banking, especially for LLCs.

Regarding the transparent LLC owned by the Cyprus Trust, it might cause some banking headaches. Banks tend to be more cautious with complex structures like that.

As for your employment and the non-grantor trust status, you should be fine as long as you're not involved in the day-to-day operations of the company. The key is to ensure that the company is managed by independent directors and that you don't have any control or beneficial interest in it.

A cool thing to consider is getting a brokerage license in Seychelles or Mauritius. This would allow you to trade directly through your company, potentially reducing costs and providing more flexibility. And, of course, a license would avoid possible bank account blocking after they learn that you provide trading services.

Tax laws and regulations can be complex and change frequently. It's always best to consult with a qualified tax advisor to get tailored advice.

Would it be comfortable for you to jump on a call to discuss all the details?