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I closing a transaction in Hong Kong. I live in the USA. We want to assign the transaction/contract to a Hong Kong Corporation that we (US Citizens) ouwn. I understant there is no corporate tax, dividend tax, capital gain tax in Hong. If we leave the money in Hong Kong are we taxed in the US? If we bring monies to the USA, we would tax at the applicable rate. Is this correct???
REPLY:
If you own the entity directly and more than 50% of the shares are owned by US persons, then it is a Controlled Foreign Corporation (CFC) and the company would be technically liable for a substantial tax burden no matter what you do. This is a very complicated subset of the tax law and you really ought to seek the counsel of a high-end US tax law firm, especially if the amount of money in question is substantial.
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