SkyAndSand

Oh, I didn't know that. Thanks a lot!

Yes, I use macOS as development VM on a maxed out 16 inch M1 MacBook Pro. It all works as expected, except you don’t have any VM settings (e.g. how much ram / cpu you want to give the VM) and Docker doesn’t run inside the VM.

My two cents: Introduce a wealth tax that only kicks in after $1B or even $10B so people still have plenty of motivation to work and get rich.

You are allowed to keep control of a company, (e.g. Elon can keep control of Tesla), but then the stock has to be structured in a way that all financial gains are in a separate vehicle that will be taxed 100% as soon as the stock is sold.

Finally (and most crucially), the money raised by this “tax” will not go to a governments pot but directly be distributed as cash to all Americans to make sure that it can’t be wasted by bureaucrats nor used for partisan purposes.

Basically, if $500B is raised in wealth tax in 2022, by mid 2023 every American gets ~$1500 in cash to spend.

What do you think?

Speaking from experience - yes you can create a LLC without being a US citizen or green card holder. You also can get bank accounts with Wise and Mercury for your company without traveling to the US.

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

Understood, I sent you an email.

I do, what do you want to know?

Why do you need my email for that? :)

I’d also love to learn more. Sounds interesting!

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?

I understand that. But why would a US company need a NL bank account?

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?

Very interesting setup. I’ll have to think a bit about that. Thanks for the write up.

Are you sure? Because at the YC doesn’t invest in them unfortunately.

Well, you have these jurisdictions already (e.g. Cayman). However if the employees are all based in other countries then you’ll always have to comply with employment regulations there.

Thanks for the offer. Will get in touch later but I think that public replies could hopefully be helpful for others.

The setup sounds great! I assume that you flipped to a C-Corp? Are most of the founders in the US or are you living abroad? How long did it take to flip the UK LTD? Do you force your contractors to set up companies or is it up to them?

At least if the contractors are in Germany and are working full-time for you then I think they would get issues with “Scheinselbständigkeit” if they don’t have a company, that’s why I am asking.

Is that an assumption or are you speaking from experience?

That is interesting! Which bank did you end up with finally and how did you convince them? Couldn’t you use something like Wise in the beginning?

That is good advice. What would you do in case there wasn’t a US founder?

Well the question is - will owning a share in a US entity make you a “US Person”?

My initial assumption that seems to be confirmed by HSBC and the ATO is “no”.

Yes, that is a good point which applies to a lot of high-tax countries. If you are a single company founder and run a company in jurisdiction B from country A then country A will usually have provisions that the company will be resident in A.

The question that I am wondering about is more like - you have four founders with 25% each who live in four different countries.

Where is the company resident in that situation?

Totally agree, but why would you need a corporate bank account in Germany? You could simply use the US bank accounts?

Yes, but besides Cayman I don’t think investors would really be happy to invest in tax havens. Also you normally run into issues with substance requirements, opening bank accounts, bad reputation of the jurisdictions and of course tax authorities that will immediately question and investigate your setup.

From doing a lot of research I get that the general recommendation is to avoid tax havens (at least the obvious, shady ones - US, Ireland, Netherlands etc. are of course fine).

Well, wouldn’t a company like GitLab run into the same issues if most of their employees are not in the US?

And that it actually won’t be recognized as legal entity after Brexit if it is based in Germany: https://www.ihk-krefeld.de/de/international/aktuelles/brexit...

While I generally agree I am wondering if this still applies if you have multiple founders in multiple countries.

Eg the founders are living in Germany, Australia and the US. The company is a German GmbH. You’d probably not automatically create PEs in Australia and the US just some of the founders living there?

Careful, many countries (especially in the EU) look “through” the trust if there is only the slightest notion of you controlling it.

Generally, in order for the trust to be fully recognized all assets have to be irrevocably owned by the trust and you can’t exercise any control over them as soon as they are transferred.

Thanks for the detailed answer.

I actually don’t live in Germany but this is definitely an interesting setup. I might actually run it by my German tax consultant to see what he thinks about it just out of curiosity :)

I see your point, but do you actually know any big, international startups that are incorporated there? I only know if Brave (the browser).

I had the same assumption. However the last notary that I worked with didn’t hand in documents in time (which caused lots of trouble), handed in incorrect documents and simply did not answer to emails or calls for weeks.

He only started to act when I used my lawyer to threaten him. Even then my lawyer said that it would be very hard to start legal proceedings against the notary.

If you think notaries are 100% trustworthy you should also have a look at https://www.tagesspiegel.de/berlin/millionen-immobilie-in-be...