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Ask HN: What is the best jurisdiction for internationally distributed teams?

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Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#181
post #176

Earlier quoted context omitted.

Hey what's your email? I'm thinking about writing up a blog post with information in this AskHN

Why do you need my email for that? :)

To read a draft :) You can reach out to me here if you want jokull@solberg.is

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#182
Anyone have experience with "non-resident" US LLC ?

That would be one way to avoid corporate taxes while being established in a reputable jurisdiction?

But for online businesses I guess at some point you'd be selling to US customers, so would that complicate things?

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#183
You need to be aware that if you choose to employ remotely internationally, then you aren’t just choosing one jurisdiction — you are potentially tying yourself up in many jurisdictions.

This is because your foreign workers will have local tax obligations by virtue of being physically present in another country while working for you. It doesn’t matter what’s written in your contracts, local law wins. They can also claim rights under their local employment law, and those countries could deem you to be operating locally and subject your company to corporate registration, reporting and taxation.

Be careful to analyse the local laws and tax situation before hiring people in another country.

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#184

If you intend to get VC funding, then you have to "keep it standard." Don't do anything new, weird, etc. The "Cayman-delaware sandwich" is quickly becoming the go-to structure for Latin American startups. It's well known and has a ton of advantages, but I believe it only works if your business is not actually US-based: if the bulk of your customers are in the US, for example, then you might have to do a Delaware corp…

What exactly does the Cayman Delaware sandwich look like? Cayman Holding and Delaware C Corp as operational company? What is the purpose of the Cayman holding then?

The Delaware company is an LLC which then owns all the operating companies in-country (which you will need, if only for payroll/hr /payments/tax/vat reasons).

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#185

Anyone have experience with "non-resident" US LLC ? That would be one way to avoid corporate taxes while being established in a reputable jurisdiction? But for online businesses I guess at some point you'd be selling to US customers, so would that complicate things?

I do, what do you want to know?

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#187

Earlier quoted context omitted.

So basically you are a group of non US citizens living in the US and wanted to have a shared entity to do investments? Well I guess then a Delaware C Corp is the logical solution? Did you use Stripe Atlas to set it up?

Yes, right on the money. Though there's a slight natural difference for us to accommodate later participants. Yeah, we used Stripe Atlas, though none of the startups we run are through that. Overall, quite painless to be honest.

Awesome, thanks. May I ask why you went with the C Corp and not an LLC? Probably to make it easier for new investors?

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#188
Among the ones you mentioned, Singapore.

If you're happy to relocate / create substance (director, offices, employees, board meetings) in another country so that the tax man in your countries of residence won't pursue you, then I'd go with Dubai or some zero tax Caribbean island if you don't care about Anti Money Laundering regulations (aka you don't care about investing the profits in European / American banks). Malta at 5% if you care about accessing European markets (even better if you have residence somewhere with little or no dividend tax like Portugal with NHR or Cyprus at 2.5% extra).

Company formation / bureaucracy is generally not a big concern, just avoid Germany, Italy, Spain, France (no reason to pick them to do business anyway) and get an accountant to deal with the pain.

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#189
post #74

Earlier quoted context omitted.

> Because of the US FATCA law you may have trouble opening a bank account in some countries (smaller entities simply can’t be bothered with the paperwork the US demands on accounts for “US Persons”, a term which has specific meaning). In practice this just means you have to deal with larger banks. You mean opening a bank account personally or for the company? Because for the company I'd simply use Wise or Mercury and…

Last time I looked it's hard to use something like Wise as your bank for your payroll. Wise has been great for managing my personal payments, but I still have personal bank accounts in a couple of countries where I hold property because it just makes things easier there.

Wise is not very business friendly yet (they're probably busy planning their next rename), better to use Airwallex

Re: Ask HN: What is the best jurisdiction for internationally distributed teams?

#190
Be careful with the offshore jurisdictions. The low taxes can be offset by a lot of weirdness and org crime. It works if you’re a big corporate and have the right protection. Everyone knows each other in the small islands and scams get run from MITM attacks in local cafes, profiling from people in restaurants/cafes/coworking and a general lack of confidentiality among islanders between people they’ve known all their lives. Also there’s a level of hostility towards outsiders being successful in some of the offshore locations even though their economies depend heavily on such investment. I speak of Isle of Man, Guernsey and Jersey but there are horror stories from some of the Caribbean islands too. Again YMMV but if they do target you expect major friction in kind of the manner the Chinese do to force you to go through a local “partner”.
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