HK corp with US branch as income-pass through

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schockergd

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Dec 11, 2008
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Circleville Ohio
I know someone here can answer this, or point me to someone who can.

My HK corporation formation is almost done. However now I'm having a issue finding out the best method for doing the business formation inside the US that will allow me to freely pass income through (Or at least not overly tax it) through to the HK corporation where my investor money is.

I will be a part owner of the US corp, whether it be a LLC , S-Corp or C-Corp. I will take a monthly salary from this corporation which from what I can tell will benefit the cashflow since it's NOT going to be a completely shell corporation.
 
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From what I understood it depends on what your company is doing in the US. If you are buying products and selling them in the US with a US merchant account this is considered effectively connected income to a US business and you'll be taxed at graduated rates. Here is an article about it:

http://www.lacba.org/Files/LAL/Vol32No5/2614.pdf

There may be ways around this, but I don't know. Consider trying to avoid accepting money inside the US if possible (you can still have US clients, just don't take money from them to a US account)
 
nickCR said:
From what I understood it depends on what your company is doing in the US. If you are buying products and selling them in the US with a US merchant account this is considered effectively connected income to a US business and you'll be taxed at graduated rates. Here is an article about it:

http://www.lacba.org/Files/LAL/Vol32No5/2614.pdf

There may be ways around this, but I don't know. Consider trying to avoid accepting money inside the US if possible (you can still have US clients, just don't take money from them to a US account)
Click to expand...

I already talked to the OP. He's not trying to avoid nor evade taxes.
 
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