i have a client(us citizen) who wants to go into business(sell/install software) with a brazilian national. alot of the business will be in latin american countries while based here in fla. sub-s is not available to non US shareholders but as far as i can tell a 2 member LLC should present no "ownership of business entity" type problems. 50/50 interest. any thoughts or other options i should look at (as regards business form)?? thanks for any responses.
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Many foreign countries do not recognize the LLC, so I would want to know how the company would be treated in the countries where it does business, as a partnership, or ?? for tax purposes and registration laws.Last edited by taxmandan; 01-16-2007, 08:05 PM."A man that holds a cat by the tail learns something he can learn no other way." - Mark Twain -
LLC Membership
An LLC is not an entity type that is recognized by federal tax law. An LLC is an entity that is established and defined by state law.
For federal tax purposes, the LLC has to make an entity election. In general, there are only four possibilities:
(i) Sole proprietership, generally available only to a single-member LLC
(ii) S-corp, not available if one shareholder is not a US resident
(iii) C-corp
(iv) Partnership
Burton M. KossBurton M. Koss
koss@usakoss.net
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The map is not the territory...
and the instruction book is not the process.Comment
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reciprocal tax treatment...
there is reciprocal tax treatment between brazil and the US thus avoiding double taxation for brazilians receiving foreign source income.
it seems to me an acceptable business form would be the LLC taxed as a partnership, assuming no other complicating factors. i will also recommend a formal agreement to be drafted by an attorney who should be able to confirm/or not my LLC recommendation.
thanks to both koss and tmd.Comment
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