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I believe that the US tax code specifies that if an individual owns more than 10% of an offshore corporation, it has to be declared on the individual's tax return.
That said, a "company limited by guarantee" has no share capital, it merely exists as a club or for some other charitable purpose. It raises the question of "does the company director have to declare the existence of this corporation on his individual tax return?
The "company limited by guarantee" does not exist to pay the principals a salary, merely reimburse costs/expenses if incurred. It stands to reason that if a person is paid from an offshore corporation, they will be liable for taxes to whatever government jurisdiction they live in (or risk money laundering charges).
Also, which IRS publication could one find information about offshore requirements?
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