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| Name | [ Offshore Tax ] US Taxation of Corp Subsidiary in Singapore |
| Video Uploader | Video From Offshore Tax with HTJ Tax |
| Upload Date | This Video Uploaded At 20-02-2022 08:34:41 |
| Video Discription | [ Offshore Tax ] US Taxation of Corp Subsidiary in Singapore If you need #InternationalTax advice? We are here... Here are 4 ways we can help you - 1. We offer HOLISTIC strategies to help you live that international life. Tax + MIGRATION options. 2. We help you MODEL the tax impact of moving to a new jurisdiction 3. CONTACT us for tax optimization consults over Zoom 4. High Net Worth? We can QUOTE for doing your "US - International" tax returns DERREN JOSEPH: So, if you have a company in the US and that US company has a subsidiary in Singapore with that company in Singapore, be subject to US taxes? Now that's a good question. Under some circumstances, the answer could be yes. And so, the US has a number of what we call anti-deferral rules. Then the one in particular tends to be triggered by companies incorporated in a relatively low tax jurisdiction like Singapore but is it's incorporated in Singapore, but it's owned or controlled by US persons. And what I mean by US persons, it could be a US holding company, or it can be US exposed individuals. So, your Singapore, and you move to the US for the purpose of running one particular company, but you leave other companies behind that. You still control those companies can be subject to different taxes. And the one that I want to draw your attention to have that conversation with your advisor would be the GILTY regime. So, the GILTY stands for the Global Intangible Low Tax Income tax. So, that calls it GILTY right? But basically, it's a tax on, on income that even though it may not be distributed to you, because typically you would imagine that, hey, I'm in the US. I run; I have a controlling interest in a company in of the US in a low tax jurisdiction. For example, in Singapore, Hong Kong, I would typically only be taxed on distributions from that company. So, distributions in the form of like, if I get some sort of consulting fee, or I take a salary that be taxed because I'm now US exposed. Or if I receive dividends after a profitable year, I take dividends, then that will be taxed. But there are circumstances where even though you did not take any money from the company, you're deemed, and the company is profitable, you are deemed to have taken a distribution. And that distribution was subject to the tax, that ordinary tax rates, and then deemed distribution can take many forms. But the one that we see most commonly with entrepreneurs who are US exposed or companies in Singapore would be the GILTY tax regime. So again, that's one to have a conversation with your advisors, so that any subsidiary in Singapore that is controlled by anyone in the US may be subject to the GILTY tax, there are other anti-deferral rules, for example, the flick regime. So, for example, if you own real estate using a holding company, or you have a holding company structure, and you have different subsidiaries that holding company could also be subject to deemed distribution or rules. So, the different types of distribution rules I said most common would be GILTY where when it comes to operating companies. But if it is that you have a holding company structure, a company that's generating passive that's involved in a passive activity, as opposed to being an operating company. So is more like a holding company that may be subject to the PFIC rules of Passive Foreign Investment Company rules. So the bottom line has that conversation with someone to understand the tax implications of moving to the US not just to run the company that you're moving to the US to run. But the other investments that you leave behind in Asia have a conversation to make sure you understand the implications of those. VOICE-OVER: Please subscribe, like, share, and comment below. Our books and upcoming events are available at HTJ.tax. Email us at help@htj.tax to engage us to advice on international tax or business matters. #OffshoreTax #internationaltax #taxplanning #financialplanning #taxes #compliance #AdaptOrDie #internationalbusiness #offshore #expats #investors #offshore #liveyourbestlife #flagtheory #InternationalEntrepreneur #entrepreneur [7B5OstSkY44] |
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