Free offshore tax comparison calculator from Fynvorax. Compare home-country corporate tax to offshore structures and U.S. LLC planning scenarios.
Substance and ETBUS (effectively connected trade/business) rules determine if offshore profits face U.S. tax. Shell companies without people/offices in low-tax jurisdictions increase audit and penalty risk.
ETBUS stands for 'Engaged in Trade or Business within the United States.' It is the primary IRS jurisdictional test. If you maintain direct offices, physical warehouses, or dedicated local employees in the US, you are ETBUS and your LLC's income is subject to US taxation. If you merely sell digital services, code, or dropship items from overseas utilizing independent local contractors, you are NOT ETBUS, rendering US tax liability at zero.
Yes. Unless you physically relocate or establish residency in a territorial tax country (like Dubai, Paraguay, or Malta), your home country's global taxation principles mean any dividends or personal withdrawals from your US LLC must be declared as local personal income, though you save the entire local corporate tax layer.
Effectively Connected Trade or Business — U.S. tax concept for foreign entities with real U.S.-connected operations; misclassification triggers penalties.
Requires economic substance, arm's-length pricing, and compliance with CFC/GILTI/transfer pricing rules — not just a mailbox.