US tax attorney / international tax advisor — review for foreign-owned New Mexico LLC
Worldwide
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/weekHourly
- 1-3 monthsDuration
- IntermediateExperience Level
$20.00
-
$100.00
Hourly- Remote Job
- Ongoing projectProject Type
Skills and Expertise
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
- United StatesAlbuquerque4:05 AM
- $59K total spent169 hires, 20 active
- 11,459 hours
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