Well, a UK LTD will be liable for UK CIT, the US LLC can be a pass-through entity.
@startfleetio knows about US company formation.
@CaptK I know he has formed some UK companies for people here. Maybe he can also suggest alternatives to the UK Ltd
I'm not sure if a UK LTD is the best for this if you live in Thailand thus with territorial taxation. You could also consider a US LLC with a holding structure.
LTD is easier as it's only one person required but you would need to do accounting to minimise you CIT. LLP is like an LLC but the only difference is it needs 2 directors one can be a an LTD which is owned by the same person. The benefit is there is no CIT as it's a pass through entity and profits are paid to the general partner.
So you will be personal liable for all what is done in the company with an LLP and LLC ?
I understand you refer to tax liability to which the answer is yes (with very few exceptions). Income earned through these types of entities is generally considered personal income of the members/partners and taxed as such. It gets complicated if you form a foreign LLP/LLC while resident in a jurisdiction that either doesn't recognise those entities or treats them as ordinary companies, though, so check with a local attorney first.
The way the question is worded, though, could imply other forms of liabilities (legal liabilities, credit liability), and those are normally limited to the company, meaning you cannot for example be sued for a debt your company has incurred. This limitation of liability is quite robust and typically only broken in cases of criminal activities with ample evidence.
Run a clean business and you shouldn't have any personal liability problems under UK or US law.
sebastian said:
So as an an foreigner I could care less about tax lability in the USA or UK with a LLC or LLP ?
Whether you care or not is a personal decision.
For a US LLC trading in the US, you need to be mindful of Effectively Connected Income (ECI). It's rarely a problem but you'd be wise to investigate it and assess how it affects you.
For a UK LLP, similar risks can exist if you trade a lot in the UK but it's generally unproblematic for non-resident foreigners to not pay UK income tax for income earned through an LLP.