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Question

i am an australian company setting looking to set up a business in U.S.

We will have an outsourced call centre n N.J and also an outsourced assembly plant in N.J.
The U.S entity therefore at least initially will have no staff.
The company will be managed at least initially from Australia.at some point we may look to have

The U.S company will be wholesaling a product that is imported from Asia and then finished in U.S

My question is what structure in what state should we set up to minimise taxation in what state ?
What are the taxation implications as the company will be owned by a non resident entity.

Submitted: 86 days and 9 hours ago.
Category: Tax
Value: $16
Status: CLOSED
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Optional Information

Country/State/Province of question: australia

Already Tried:
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Accepted Answer

As long as your business will have a nexus in NJ - and therefore will be under the jurisdiction on that state - I would suggest to register the company in NJ.

Depending on the size of your business operations - you may have LLC, LLC with S-corporation treatment selection, or C-corporation.

There is no simple solutions and all circumstances should be analyzed.

See a brief comparison each type of business structure here - http://www.hrblock.com/tax_business_services/resources/article_bus_struc.html

 

Please also be aware of US-Australia income tax treaty - http://www.irs.gov/pub/irs-pdf/p901.pdf

Income that residents of Australia receive for performing personal services as independent contractors or self-employed individuals (independent personal services) in the United States during the tax year is exempt from U.S. income tax if the residents:

  • Are in the United States for no more than 183 days during the tax year, and

  • Do not have a fixed base regularly available to them in the United States for the purpose of performing the services.

If they have a fixed base available in the United States, they are taxed on the income attributable to the fixed base.

Pay that residents of Australia receive for labor or personal services performed in the United States as employees (dependent personal services), including services as a director of a company, is exempt from U.S. income tax if:

  • The residents are in the United States for no more than 183 days during the tax year,

  • The pay is paid by, or on behalf of, an employer or company that is not a resident of the United States, and

  • The pay is not deductible in determining the taxable income of the trade or business of the employer (or company) in the United States.

Let me know if you need any help.

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Expert: LEV
Pos. Feedback: 99.3 %
Accepts: 
Answered: 8/28/2009

Tax Preparer

Taxes, Immigration, Labor Relations

86 days and 7 hours ago.

Reply

 

If i set up an LLC owned by an Australian Company (or unit trust) what are the taxation implications of this set up ?

 

What taxes are payable ?

 

Is it possible to reduce taxes claiming that the entity is managed offshore ?

 

If the LLC was set up in Delaware or Nevada is this alloed and it has taxation benefits ?

 

 

86 days and 7 hours ago.

Reply

 

If i set up an LLC owned by an Australian Company (or unit trust) what are the taxation implications of this set up ?

What taxes are payable ?

Is it possible to reduce taxes claiming that the entity is managed offshore and what other issues do we need to be aware of ?

If the LLC was set up in Delaware or Nevada is this allowed and it has taxation benefits ? Yes we N.J phone, fax and address but i don't have people on the ground ... its just a virtual office

Do we have to registar in each state that we transact?

Do we have to register to import products?

f we are not selling to the end customer then is there no VAT applicable ?

 

Posted by LEV 86 days and 7 hours ago.

Answer

Please see my comments after each question.

 

If i set up an LLC owned by an Australian Company (or unit trust) what are the taxation implications of this set up ?

Unless the selection is made - the LLC is not taxable entity - all taxable income is passed through to members - in your situation - to an Australian Company - wish will be taxable as a foreign entity - most likely as a foreign corporation.

What taxes are payable ?

Income tax on net income - federal and state, excise tax depending which product will be sold, employment tax, sales tax - will be collected from buyers

Is it possible to reduce taxes claiming that the entity is managed offshore and what other issues do we need to be aware of ?

that will have no affect on the tax liability

If the LLC was set up in Delaware or Nevada is this allowed and it has taxation benefits ? Yes we N.J phone, fax and address but i don't have people on the ground ... its just a virtual office

As long as you will have a nexus in NJ - you would need to register in this state.

Setting LLC in another state might help if you do not have a nexus in the US.

 

Do we have to register in each state that we transact?

You need to register in each state in which you have a nexus - a physical presence.

Do we have to register to import products?

Depends on the type of product - you might have to hay import duty

If we are not selling to the end customer then is there no VAT applicable ?

there is no VAT in the US.

 

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