(Rev 2017-11-25)

Starting in the early 1980s the United States was made into the largest tax and regulatory haven in the
world for foreign nationals not resident in the U.S. This policy change has been wildly successful, pulling
in trillions of dollars of capital into the US economy.

The U.S. has numerous tax treaties and, like many nations, complicated, ever-changing tax laws
administered by an often confused or irrational tax bureaucracy. If more than $10.000 is taken into or out
of the U.S., outside of normal banking channels, a report must be filed with the customs authorities.
However, the combination of double taxation treaties and the fact that foreign tax authorities do not
generally consider the U.S. a tax haven can, results in a very favorable overall situation.

The best tax avoidance solution for foreigners is a U.S. Limited Liability Company (LLC). This
company can be used exactly in the same way as any offshore business company registered in any Tax
Haven, as long as it does not trade with the United States. The Limited Liability Company (LLC) is a
hybrid with similarities and differences with other business forms:

• It is a separate legal entity like a corporation
• It does not have shareholders, but rather it has members.
• Their personal liability is limited to the amount invested in the LLC
• For USA incorporation the members can be physical persons or legal entities, including corporations,
partnerships, trusts etc.
• Non-residents can be members of the LLC.
• The LLC is taxed like a U.S. partnership with the benefits of flow-through taxation.
• The LLC can be formed with any number of members.
• An LLC does not pay taxes.
• Foreign members are not liable to U.S. tax if the income is not from United States sources.
• The only document required to register an LLC with the local Secretary-of-State are the Articles of
• An LLC may have a limited life span.

A US organized Limited Liability Company is for persons who conduct international business and wish to
minimize their tax liability. A U.S. Limited Liability Company (LLC) allows Non-US resident full ownership.
These members are not required to file any tax returns if the income of the LLC is not effectively
connected with trade or business within the United States and if the LLC employ no U.S. residents
and does not rely on a dedicated place of business within the United States.

Incorporation Services
Any State:

Opening a U.S. bank account generally requires a trip to the U.S.A. Fortunately, there is no legal 
requirement for a U.S. company to have a U.S. bank account, nor is there a requirement to use the US$
as the primary currency. We recommend a Borderless Accout offered by Transferwise: .

Keeping accurate books is a legal requirement. Books can be kept in any currency. If books are kept in
US$, we recommend WaveAccounting: . If books are kept in a foreign
currency, we recommend Brightbook: .

U.S. Tax Compliance
1. The LLC is required to file an annual US tax return by March 15 of year following the tax year,
Federal and State (if applicable). This is an information return. The LLC is not a taxable entity.
2. Members who are U.S. citizen and green card holders of a U.S. LLC residing overseas are
required to file an annual U.S. tax return.
3. Members who are foreigners. and not U.S. Residents, generally do not have to file and pay U.S.
taxes on LLC earnings.

Virtual Office
1. Most U.S. incorporation services provide a virtual office facility.
2. If not, we recommend MailboxForwarding:
3. Registering a Representative Office in your country of residence is a recommended prerequisite.
The Rep Office is a cost center for the parent LLC, and allows the LLC to hire and pay local staff
and services.

Italian Tax Compliance
1. Italy taxes its Residents on their worldwide income no matter its source.
2. LLC distributions are considered dividends under the Italian tax system. Only 49.72% of the
distributed income (dividend) is taxed by Italy.

Legal Matters
It is highly recommended that an entrepreneur seeks local professional legal and fiscal advice before
incorporating in the U.S.A.