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 留美人士回国创业税务必读(2)-Controlled Foreign Corporation 补充： |
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(none) -- hwarrensen - (0 Byte) 2003-5-14 周三, 00:38 (474 reads) |
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作者：游客 在 海归商务 发贴, 来自【海归网】 http://www.haiguinet.com
You questions are very good. But FCF rule applies to both natual person and corporations. When IRS first proposed FCF, it was for US corporations. Old days, many big US corporations such as citibank, GM... set up wholly owned offshore corporation in tax-haven and then keep all their international profit in offshore. IRS issued CFC rule to force them to pay US tax. If an offshore Corp 's ownership is 50% + owned by US corporations or if one US corporation owned an offshore corp more than 10%, then this US corp has to pay for CFC tax accordingly. Therefore, you have to pay for US tax if your LLC, S corp or C-Corp owned 10% or more shares of an offshore corporation. If you really want to avoid to pay this tax, consult a good TAX Lawyer. There are many tax lawyers may be able to suggest you a structure so that you can indirectly own what you want to own but avoid to pay this tax legally. I know some way but it is quite complicated and I don't want to mislead you publically. Better to do more homework. As an American, we have to follow the law. Don't believe some body else's irresponsible suggestions that IRS will not or can not find you..
Good luck..
作者：游客 在 海归商务 发贴, 来自【海归网】 http://www.haiguinet.com
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