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	<title>Comments on: Avoiding the US/UY tax trap&#8230;</title>
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	<link>http://www.uruguayliving.com/2006/11/03/avoiding-the-usuy-tax-trap/</link>
	<description>Broken promises and failed hopes...</description>
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		<title>By: Seasons</title>
		<link>http://www.uruguayliving.com/2006/11/03/avoiding-the-usuy-tax-trap/comment-page-1/#comment-415</link>
		<dc:creator>Seasons</dc:creator>
		<pubDate>Sun, 05 Nov 2006 12:32:24 +0000</pubDate>
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		<description>*phew* Yes, makes sense now.

Forgive me for all the questions- I&#039;m a writer/designer, wrapping my mind around mathematical things is sometimes like trying to squeeze a square peg in a round hole...repeatedly.

&gt;&gt;Don&#039;t feel badly about it--I am almost ashamed that I understand this stuff; seems like it ought to be prima facia evidence of a disturbed mind...</description>
		<content:encoded><![CDATA[<p>*phew* Yes, makes sense now.</p>
<p>Forgive me for all the questions- I&#8217;m a writer/designer, wrapping my mind around mathematical things is sometimes like trying to squeeze a square peg in a round hole&#8230;repeatedly.</p>
<p>>>Don&#8217;t feel badly about it&#8211;I am almost ashamed that I understand this stuff; seems like it ought to be prima facia evidence of a disturbed mind&#8230;</p>
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		<title>By: Seasons</title>
		<link>http://www.uruguayliving.com/2006/11/03/avoiding-the-usuy-tax-trap/comment-page-1/#comment-414</link>
		<dc:creator>Seasons</dc:creator>
		<pubDate>Sun, 05 Nov 2006 08:20:46 +0000</pubDate>
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		<description>Ok, thanks. Maybe I missed something obvious but when the LLC pays me dividends...won&#039;t that become taxable by the US again?

&gt;&gt;You missed the first main point.Â  If the LLC is considered a &quot;disregarded entity&quot; for US tax purposes, you will have paid personal US taxes on all of its income already, and if all of that income was earned income while you were a non-resident, it will be subject to the US$80,000 exclusion.Â  In other words, when an entity is disregarded for tax purposes, it is as if you earned that money directly, at least as far as the IRS is concerned.

So when the LLC pays you dividends, it will be non taxable income in UY, and from the IRS point of view it will simply be a nontaxable transfer of funds from one account to another.

Got it now?</description>
		<content:encoded><![CDATA[<p>Ok, thanks. Maybe I missed something obvious but when the LLC pays me dividends&#8230;won&#8217;t that become taxable by the US again?</p>
<p>>>You missed the first main point.Â  If the LLC is considered a &#8220;disregarded entity&#8221; for US tax purposes, you will have paid personal US taxes on all of its income already, and if all of that income was earned income while you were a non-resident, it will be subject to the US$80,000 exclusion.Â  In other words, when an entity is disregarded for tax purposes, it is as if you earned that money directly, at least as far as the IRS is concerned.</p>
<p>So when the LLC pays you dividends, it will be non taxable income in UY, and from the IRS point of view it will simply be a nontaxable transfer of funds from one account to another.</p>
<p>Got it now?</p>
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		<title>By: Seasons</title>
		<link>http://www.uruguayliving.com/2006/11/03/avoiding-the-usuy-tax-trap/comment-page-1/#comment-412</link>
		<dc:creator>Seasons</dc:creator>
		<pubDate>Sat, 04 Nov 2006 05:32:32 +0000</pubDate>
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		<description>Back on the original topic:

If I currently run an LLC can it become a â€œdisregarded entityâ€ when I leave the US or must I form a new one just for such a purpose?

&gt;&gt;It depends on how it is taxed now--changing can sometimes can tax issues, and if carrying it outside the US might adversely affect issues like &quot;effectively connected income&quot;.Â  Since you can get a new LLC, either in Delaware or the Marshall Islands for about US$1,000, it is rarely worth continuing an existing working US LLC.</description>
		<content:encoded><![CDATA[<p>Back on the original topic:</p>
<p>If I currently run an LLC can it become a â€œdisregarded entityâ€ when I leave the US or must I form a new one just for such a purpose?</p>
<p>>>It depends on how it is taxed now&#8211;changing can sometimes can tax issues, and if carrying it outside the US might adversely affect issues like &#8220;effectively connected income&#8221;.Â  Since you can get a new LLC, either in Delaware or the Marshall Islands for about US$1,000, it is rarely worth continuing an existing working US LLC.</p>
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