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Topic: Draw salary/dividends from a UK CFC as sole-owner or move company to US?  (Read 711 times)

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Hi all,


I moved to the US last year and am trying to navigate the difficult transition of tax issues.

I had information back from CPAs and their is some grey area/conflict I am trying to resolve.

I had a company back in the UK that I shut-down and moved to the US upon coming here.

It is an internet based copywriting agency.

I still use quite a number of UK independent contractors and about 1/3 of orders are from UK clients.

This is leaving me concerned as to whether, if I continue in this way, I may be consider to have a permanent establishment/dependent agent in the country (sales rep) and if services are performed there (contractors) they may be liable for VAT.

The options I am exploring are:

1. Stay as a US LLC but reduce my reliance on UK contractors, taking on US employees/contractors to replace them.

The sales agent is quite an important role though - I pay him commission and would like to keep him on. He has in own small copywriting service he does also so he should stand up to any questions of whether he is an employee v contractor.

2. Startup again in the UK as an LTD (VAT reg) either as a separate business, or as an LTD subsidary of the US LLC. I would keep the US LLC for US orders in the former scenario, though the companies wouldn't be linked as a branch/subsidary.

My issues with the second option are that is seems like a LOT of accountancy reporting obligations, and I am unsure how I can efficently draw an income from the business that way.

Any thoughts or feedback would greatly be appreciated. I am working with accountants both side of the pond to figure this but any second opinions/thoughts would be massively helpful.


Thanks,
Emma





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