What taxes I will pay as a non-resident of USA set up a Wayoming company
Please explain, if I as non-resident of USA set up a Wayoming company, what income of the company will be taxed in the US: all income or only part of income from sources in the US?
The beneficial owner of the company is citizen and resident of Azerbaijan.
The company will be engaged in the telecom and IT business. Namely, the company will have the following activities:
– it will act as broker / intermediary in transactions of sale and purchase of telecom assets – IPv4 and IPv6 address blocks and domain names;
– it will act as broker / intermediary in transactions of lease of IPv4 and IPv6 address blocks;
– it will rent out VPS servers;
– it will provide hosting services.
Regarding brokerage transactions:
IPv4 and IPv6 address blocks and domain names are intangible goods. Rights to IP addresses are registered by regional registries (RIPE NCC, ARIN, APNIC, etc.).
Clients (buyers, sellers, lessors and lessees) are typically from the USA, the EU member states, Russia, Ukraine, China, India.
All such transactions typically are carried out through the US-based escrow service provider Escrow.com (operated by Internet Escrow Services Inc, registered in the state of California). Initially the buyer transfers the payment toEscrow.com. After the IP address block is transferred to the buyer and such transfer is registered by the respective registry, Escrow.com pays out the money to the seller and the broker.
After becoming acquainted with the information online about Wyoming corporations, I understand that the most suitable form for this kind of business would be LLC. It is planned that the beneficial owner will be the sole shareholder and director of the LLC. As mentioned, the BO is a citizen and resident of Azerbaijan, he has no links to USA.
In order to receive payments from Escrow.com and US-based clients, the LLC will open a bank account in a USA bank.
1) What kind of taxes, on what income and according to what rate will be payable by the LLC un the US?
2) Does the source of income influence whether income is taxable?
3) As regards source of income: please explain whether in my situation the source of income will be considered as a US source. As explained above, the buyer transfers purchase price to payment guarantee system Escrow.com in the USA. After delivery of IP address blocks, Escrow.com disburses to me the brokerage fee. Technically the incoming payment is from a US corporation operating the Escrow.com payment guarantee system, however the ultimate transmitter of funds is the buyer, which may be a US company and may be a foreign corporation.
4) Does opening of an office in the state of Wyoming and hiring a local director change the taxable income and tax rate?