Tax Advisor - Setting up new entities and structure

Posted 2 weeks ago

Only freelancers located in the U.S. may apply.U.S. located freelancers only

Summary

We're setting up a new US entity structure for a foreign-owned (Netherlands-based) company and need a quick consultation from a US tax advisor before we finalize entity types and states of formation. The proposed structure includes four new entities: A Delaware holding company (100% owned by a Dutch B.V.) A Delaware operating company underneath it (handling US invoicing, collections, and vendor payments) A Delaware LLC that exists solely to hold a 50% stake in a joint venture A Tennessee LLC that is the actual joint venture (50/50 with an outside US partner), with production operations based in Arizona What we need: A review of whether each entity should be a C-Corp or an LLC, factoring in the foreign ownership chain (S-Corp election isn't available given the Dutch parent) Guidance on state of formation/qualification given multi-state operations (Delaware entities, Tennessee JV, Arizona production) A high-level view of how each choice affects: double taxation exposure, US-Netherlands tax treaty treatment of dividends flowing to the Dutch parent, Form 5472 filing obligations, and ongoing compliance burden A short written recommendation we can bring back to leadership — doesn't need to be exhaustive, just enough to make an informed decision quickly Ideal candidate: CPA or tax attorney with experience in foreign-owned US entity structuring (inbound international tax) Familiarity with Delaware and multi-state corporate/LLC formation Available for a call today/tomorrow — we're trying to close this out quickly and start incorporations Scope: One-time consultation, likely 1-3 hours of work. Open to ongoing engagement afterward if it's a good fit for future filings. Please include relevant experience with foreign-owned US structures in your proposal.

  • Less than 30 hrs/week
    Hourly
  • < 1 month
    Duration
  • Expert
    Experience Level
  • $50.00

    -

    $75.00

    Hourly
  • Remote Job
  • One-time project
    Project Type
Skills and Expertise
Tax Law
Tax Preparation
Activity on this job
  • Proposals:5 to 10
  • Last viewed by client:4 days ago
  • Hires:
    2
  • Interviewing:
    2
  • Invites sent:
    0
  • Unanswered invites:
    0
About the client
Member since Sep 19, 2022
  • United States
    Tucson10:42 AM
  • $21K total spent
    34 hires, 11 active
  • 1,832 hours

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