Comments by "Jeremy Barlow" (@jeremybarlow2291) on "Nomad Capitalist"
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They are most definitely upset about digital nomads in Europe, Canada, and the USA extricating themselves from the Western tax base by for Europeans and Canadians, moving to Dubai & setting up a free zone company, and either living there for a year or living briefly in a country with rules that allow them to be tax resident in a low or no tax country while living there for 2 months or less. After you are no longer in the European or Canadian tax system, until you legally become resident there again, I do not presently see the UAE chasing you down to tax you while you continue a digital nomad lifestyle seeing the world.
The US is upset that backpackers earning up to $120k a year or maybe a bit more if they utilize travel expenses appropriately and add the right income channels to their mix of strategies are escaping the US tax system to a large degree. They are far more upset that those people are using the tax savings to buy a Caribbean passport and renouncing their citizenship, but what they really hate is money is being spent by those "citizens" ie slaves, in other countries. What they really don't like now is that people because of YouTube are seeing people who grew up in their "first world countries" experiencing a better quality of life in poor "third world countries" with lower tax burdens, more to do, lower costs of living inspiring others to leave the rat race they created in their countries.
I mean the "first world" already has a labor shortage because Westerners are telling people in the "third-world" the opportunities are better or at least as good in your home country as they are in the "wealthy" countries. Those same people are seeing those same videos in their country. They have labor shortages exacerbated by the fact that a person with a laptop and an Etsy store can make up the salary or wages from their low wage job selling trinkets and trash online while working 10 hours a week.
They have the problem of many people ditching apartments and houses for life in a Van because minimalism and an unencumbered simpler life allows people to work less not only fueling a labor shortage, but also hurting the real estate investor market.
But when people begin to decide to leave for greener pastures by deploying those minimalist strategies, they know they cannot allow travel to be as easy as it has been in recent years. It is very bad for their incumbent player advantages.
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It's possible for a US person who has renounced US citizenship -preferably obtaining another citizenship first, if they hold a college degree, I would highly encourage a CBI in one of the OECS countries then using their membership in Caricom to obtain a skilled worker certificate to secure freedom of movement rights in Barbados, Belize, Trinidad & Tobogo and other Caricom countries. If that US person is a permanent resident of the US or a temporary worker under an H1B or similar visa, then by ending their residential connection with the US to use a US based LLC -preferably in one of the state corporate & income tax free states, Wyoming, Texas, Washington, Nevada for example, and have a tax free operation, if they live in the right country as a tax resident, and manage the company ie hold formal annual board meetings in the right country or countries.
I suggest the Caricom citizenship because under the US-Barbados tax treaty, holding a board meeting for a US organized company in Barbados doesn't make a company tax resident in Barbados. As long as there are no employees or contractors in the US, legal precedent in the US does not make this pass through entity subject to US tax, necessarily.
Under the US-USSR tax treaty which the US recognizes, but Georgia does not, the tax rate on even royalties from a US business to Georgia is a 0% withholding rate.
A company not managed and controlled or organized in Georgia with no permanent establishments in Georgia is not subject to tax in Georgia under Georgian law currently.
A high networth individual with $3 million in assets or over about $65k a year in income for the last three years who owns requisite property in Georgia and has a residency permit due to that property ownership can avail themselves of tax residency in Georgia by not being tax resident elsewhere and proving they have a high networth and maintain residency in Georgia.
This would give a digital nomad the ability to move rather freely. The republic of Georgia does not tax individuals on offshore income.
The US tax resident company per the US-Barbados treaty as a pass through entity under US law would only be taxable in Georgia under current US law if the pass through owner was tax resident in Georgia.
In this instance, even royalty payments typically subject to a 30% withholding rate in the US would have a 0% withholding rate under the US-USSR treaty which the US recognizes and as the owner & not the company would be considered the owner of the royalties, even some of the most difficult income to extract from the US tax free could pass tax free to a Georgian resident through this US LLC.
So long as a digital nomad in this scenario did not become tax resident elsewhere, by holding annual board meetings for the US LLC in Barbados, it would not be taxable in Barbados under the treaty or Georgia under Georgian law, but would be a foreign company as a US LLC.
It would still have nonresident reporting requirements to the IRS, but should not be a taxable entity, and as long as the nomad does no work in Georgia, they should not be taxable on the company profits in Georgia either.
The US LLC provides fairly easy access to good online transactional banking for an operating company and a Wyoming LLC provides strong asset protection both against liabilities of the company to the owner, and liabilities of the owner in regards to assets of the company with charging order protection.
This means if the owner got into a car wreck in a country where that being their fault could be costly, it would be almost impossible for a judgement creditor whose claims exceeded the nomad's liability insurance to liquidate the LLCs assets.
I bring this up, because it always makes me laugh that a US LLC is one of the best tax haven assets in the world for people who are not US citizens if they plan how to use it correctly.
In terms of US citizens reducing taxes, a C or S Corp or a foreign corporation in a zero tax jursdiction where economic substance requirements are not an issue with proper use of foreign residence exclusion, foreign earned income exclusion, per diems, health insurance deductions, health savings accounts, IRAs and 401(k)s, along with travel expenses can get a US taxpayer north of $200k a year tax free. The combination of a US C or S Corp with the right zero tax foreign entity as a subsidiary using a check the box election can be useful -if you can get banking for that zero tax entity.
The recent introduction of economic substance requirements in many zero or low tax jurisdictions to satisfy the OECD and avoid being blacklisted from participation in international bank clearing of transactions has made a lot of low or zero tax jurisdictions nearly impossible to use because bank accounts are hard to get, or economic substance requirements are costly to comply with in ways they did not used to be. There are exceptions, but if you want to be a nomad, then it is harder than ever before.
The way around this is proper planning, structuring and use of the right entity types in countries that are not on any blacklists which are easier to secure banking for than headline rate zero tax countries.
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Antigua is the CBI passport I would look at first in terms of bang for the buck. I would think about North Macedonia before Turkey because while I doubt it will ultimately join the EU, it might, but it gives you Japan. You don't get Thailand, but a Thai Elite Visa or a Thai Investor visa can take care of that. Would Turkey give you a few more countries visa free, sure, but are they countries likely to be at the top of your list of places to visit? Aside from Thailand which is not that difficult to obtain a visa for, not really. Kazakhstan? Mongolia? If you have the money to buy a CBI, you have the money and income to go to a Mexican consulate and get a Permanent Residency Permit for Mexico for your Antigua or North Macedonia passport which would put Mexico back on your list.
Now after that, Bulgaria or Portugal become appealing for getting an EU citizenship, but you need to structure your investments correctly if you are going to become tax resident in either one. They are mostly appealing for non-EU citizens. If you are already an EU citizen, having a backup citizenship like any of the Caribbean citizenships is probably a good idea in the event they ever adopt a US style citizenship based tax regime.
If you are single, then spending vacation time in any of the EU countries that offer citizenship to spouses of their citizens after a set amount of time, regardless of the location of your residence becomes appealing because your spouse potentially gives you the ability to live and work anywhere in the EU which can be helpful for structuring transactions.
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Bank accounts are the tip of the iceberg. There are also permanent establishment issues, the new economic substance test regimes, the clout to avoid banking issues or not, and the ability to benefit from double tax treaties. Where are your personnel working from is a vital question thanks to the new economic substance tests. Where is the IBC registered to operate is another question. I mean yes you are BVI corporation, but are you only authorized to do business in the BVI, or have you registered as a foreign corporation elsewhere? You haven't? Where are your personnel in the BVI, how many of them are there? Where is your managing director located? Who is that person? What ownership stake do they hold in the company? Do they have checkbook authority or are they merely a nominee director ie are they a sham?
Most of the jurisdictions which had IBCs excluding the truly territorial tax jurisdictions, ie Panama, Hong Kong and the like will tax the worldwide profits if the business is actually operating in their jurisdiction, and if you aren't, well where are you registered to do business otherwise?
It takes a lot of planning of various parts to avoid taxes as a multinational corporation which is what you personally must become to avoid taxes.
Find a video explaining the Double Irish with a Dutch Sandwich or the Double Irish with a Single Malt to begin understanding the kind of thinking that is actually involved. If you are an American add to that complexity GILTI and Subpart F, but also add to it foreign tax credits, FBAR, FATCA, and the foreign earned income exclusion. If you are in the EU -not the UK, Brexit was clearly about their overseas tax havens, but the rest of the EU, get ready for something like the US worldwide tax regime to take effect soon, and understand there are a lot of moving parts to consider.
You have to think like a multinational corporation's tax attorneys and tax consulting accountants. You need to be reading KPMG, Deloitte, and PWC reports on various countries corporate and personal income tax regimes. You need to understand how to obtain residency in favorable tax jurisdictions. You need to figure out which countries have favorable double tax treaties with the country where you situate you primary business, and which countries have regimes that will allow you to have subsidiaries with favorable transfer pricing studies to hire employees at the lowest wages and get the best performance while paying the least tax on the profits those companies must show for the services they provide to the primary company. You must figure out which country has the economic might to avoid issues with the EU blacklist. You need to figure out how to get money out of major markets with withholding regimes like the 30% tax the USA imposes on most transfers of money out of the country, except to jurisdictions who benefit from favorable double tax treaties and you must probably find such countries which have favorable double tax treaties with your primary country for your business because they likely aren't the same country.
You also need to figure out how to get proper transfer pricing studies done to make sure that the countries in question do not take issue with transfers out of their country of the profits those subsidiaries earned without taxes inside those nations being imposed.
You are going to need to understand IP licensing, loans and interest payments for this, or you are going to need to find low tax jurisdictions for this to work.
There are a million moving parts to international tax planning, and that is what Andrew is trying to say, without saying it.
You can figure this all out on your own if you are a lawyer or an accountant working at an international tax planning consultancy. If you aren't and you have the 120 IQ needed by most to complete graduate school, you can probably figure it out too, but it will take a lot of reading and research. It will probably take hiring translations for various treaties and statutes as well because there will be a lot of languages that laws and treaties you need to worry about are written in that you probably won't be able to read.
Hell there may even be treaties in effect as far as one country is concerned that another country disregards that would be a huge advantage to you which you will need to figure out how to use regardless.
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"Nothing will fundamentally change." -Joe Biden to a room full of well to do contributors.
So far the leadership in Congress and his own actions have shown his policies & their policies do not differ significantly from those of the Trump Administration.
This to me means that the destabilizing effect on democracy that the previous administration had on the United States is likely to worsen. The US has been a flawed democracy for quite some time & the failure of leadership & vision inside the United States to address the challenges facing the nation due to crony capitalism's consolidation of power & anti-competitiveness, the failure to alleviate pressures stemming from income inequality by implementing policies that will alleviate overly burdensome healthcare expenses on American business while providing better coverage for all Americans by implementing sensible employment taxes & regulation in place of the current private insurance scheme that is creating a disunity in the populace is hurting the country.
What I find interesting is that a country like Singapore, and a country like Uruguay have been able to implement a fairly low territorial tax system, while also creating systems of universal healthcare & creating an environment that has not priced most of their citizens out of the housing market either as buyers or as consumers of quality housing, yet the United States is failing in this mission with far more land, far more resources, and a highly productive people.
The reality it occurs to me is that no political leader in America has said, we can have a tax system that provides better for the basic social welfare needs of it's citizens AND costs less for both workers & business owners than our current system.
Not one political leader in the United States has said, we can provide a system of universal healthcare and have low taxes. Singapore does this with very little government spending and has some of the best healthcare in the world with a system that is universal. Uruguay's healthcare is not the enviable system that Singapore has, it isn't even as solid as it's slightly poorer South American neighbor Chile, nor fellow Latin American territorial taxed neighbor Costa Rica whose universal healthcare system, like Chile's places it ahead of the USA.
Why am I mentioning healthcare so prominently as an issue that is causing the problems in the US?
Because it is THE issue which to a large degree stifles enterprenuership in the USA. It is also one of the two leading issues that creates significant income inequality, this despite the fact that the current system which not only leaves too many people without care, costs American business FAR MORE than all of their competitors around the world.
Can the USA adopt the Singaporean healthcare system entirely today? No, it really can't because of how the current system is designed, but it can redesign the current system to transition towards a Singaporean style system over the course of two generations. It will easily take forty years to make health savings accounts the major source of payments rather than insurers, be they private or public, but it can be done.
Hell the US could adopt an entirely territorial tax system & it would probably increase revenue returns to the treasury so long as the destabilizing pressures of the poorly managed healthcare system were addressed.
Are there other issues in regards to crony capitalism that need to be dealt with to get the US on the right track, yes, but no one in either of the two main parties in the US are in any way prepared to address them because the political leadership of the country in both parties is owned by a myopic group of kleptocratic crony capitalists who are blind to the risks the failure of the US as a democracy will have on their consumer base & long term business interests.
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My plan is to get a business that earns most of its income through royalties functional, move to Portugal on a D7 visa and residence and earn an EU citizenship while benefiting from the NHR and Social Security Totalization Agreement as an American self-employed in Portugal. A royalty based business has few litigation risks, and most litigation risks that could apply would not be protected by a corporate liability shield regardless, so it is a practical way to operate in terms of tax efficiency and asset protection. After gaining Portuguese citizenship, the options for how to operate and where to live become a lot easier to deal with, especially as it opens up multiple EU jurisdictions for corporate structures and tax planning because as an EU citizen I could work as a board member in any EU country. Ireland, Hungary, and Cyprus offer some solid structuring strategies. The potential tax savings while living in Portugal may also allow enough savings to purchase a Caribbean citizenship, assuming the programs remain open. Dominica's current visa-free access is probably the most appealing as a supplement and compliment to Portugal. Securing a Skilled Worker Certification for Caricom would be part of the strategy when obtaining any Caribbean citizenship.
After obtaining Portuguese citizenship, a residence permit in Mexico, Malaysia, Thailand, the Philippines, Uruguay, Costa Rica, Barbados, or Georgia would all be likely possibilities. Cyprus, Ireland, and Malta might also be in the mix for residency.
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