US citizen CFC avoidance

alfonsesimone04 said:

Hi, first post on here so I apologize if this is in the wrong place.

I am a US citizen with multiple online social casino businesses, have been heavily looking into potential offshore solutions for the past months now, and it seems like no matter the structure of your corporations and trusts you will still be considered a CFC by the IRS.

Is there any exemption if the corporation's principle place of business is somewhere else. For example if I form a Cyprus company, and have it rent and office and pay the 12.5% tax there, would this make the company non foreign controlled?

Another method of avoidance could be to have a foreign director open a bank account, but it seems like for almost all offshore banks the UBO has to be disclosed. Are there any banks that do not require full UBO disclosure?

EDIT: Another potential strategy I came accross, this one seems a bit more on the grey side is to obtain a second passport, and use that passport to open all bank accounts and leave out the info about your US passport.

Open to any other solutions. Thanks

If you want to stay on the legal side of things, then expect to disclose the UBO to the banks and forget about the 2nd passport solutions whereby you could avoid disclosing your US citizenship.
Are you licensed or looking to obtain a license to run your casino business ?

alfonsesimone04 said:

We are currently licensed, the casino business is just one. Moving into the payment processing side of things aswell.

I am open to safely grey solutions aswell. Any advice

In general the US CFC rules provides for certain exceptions. Where are your casino customers based ?

alfonsesimone04 said:

We are an online business, I plan on keeping the current US incorporated casinos in the US, but I have plans for much larger ones, as well as payment processing companies and would like to use an offshore structure for these. The majority of the merchant accounts and banks accounts are under Cyprus corporations.

What are the current CFC exceptions?

I would be completely open to renting an office, paying employees, and even paying a lower tax in Cyprus if possible.

I will send you a PM.