US tax attorney / international tax advisor — review for foreign-owned New Mexico LLC

Posted 3 weeks ago

Worldwide

Summary

I own a New Mexico single-member LLC that is manager-managed. The sole member is a foreign (EU) holding company; I am the individual manager and also an EU tax resident. The LLC is a disregarded entity for US tax purposes and files the associated pro-forma returns. I'm preparing the LLC's inaugural member-level authorisations (approving the operating agreement framework, ratifying organizational actions, an annual budget/manager-authority scope, and a related-party asset contribution from me to the LLC recorded as an intercompany payable). My EU-side corporate-services provider has pushed back, arguing that having the foreign member (or its directors) approve/ratify these items risks pulling them into "operating" the LLC and increasing their liability. I need a clear US-law read to settle this before we finalise. What I need answered (written, then a call): Which of these member-level actions are legally required to effect the structure and the asset transfer, versus advisable-for-substance, versus optional? Does the foreign member — or its directors — ratifying/approving these items create any liability or "operator/manager" characterisation for the member under US law? For the related-party asset contribution (I'm the conflicted counterparty): what's the minimum documentation, and who should sign, to keep it clean? You should have: US license (attorney strongly preferred) or CPA/EA credential with demonstrable experience in foreign-owned US LLCs Familiarity with manager-managed LLCs with a corporate foreign member, disregarded-entity tax treatment, and cross-border (EU) structures Ability to give practical, decision-ready guidance, not just theory In your proposal, please tell me: your credential, and one or two examples of similar foreign-owned-LLC matters you've handled. Proposals that don't address this will be skipped. Initial scope is a paid consultation (a few hours). If it goes well, there's likely ongoing work and possibly joining a call with my EU-side directors.

  • Less than 30 hrs/week
    Hourly
  • 1-3 months
    Duration
  • Intermediate
    Experience Level
  • $20.00

    -

    $100.00

    Hourly
  • Remote Job
  • Ongoing project
    Project Type
Skills and Expertise
Mandatory skills
Limited Liability Company
Activity on this job
  • Proposals:5 to 10
  • Last viewed by client:2 weeks ago
  • Hires:
    1
  • Interviewing:
    2
  • Invites sent:
    30
  • Unanswered invites:
    18
About the client
Member since Dec 3, 2018
  • United States
    Albuquerque4:05 AM
  • $59K total spent
    169 hires, 20 active
  • 11,459 hours

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