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Panamanian company opening a US business bank account without Nexus

Asked in Offshore (General) for Panama

The owner of my Panamanian company, myself and a few independent contractors perform international business services on behalf of global clients, some of which are US businesses.

We're considering opening a US HSBC business account in order to receive payment from these US clients. Our Panamanian company performs the "work" (services) outside the USA although one of my newest independent contractors will be located in the USA (Colorado) but his relationship is to the Panamanian company and not to the US client directly.

The idea is to accept payment to the US account and then transfer this money (or not) to the Panamanian business account. What we're mostly concerned with is the avoidance of creating a 'nexus' with the USA since, according to the IRS, payment for 'services' to non-resident alien companies does not create a nexus and can be made without withholding 30% even without a tax treaty in place if payment is for services. Why pay additional US taxes on these earning if not legally obligated to, right?

HSBC seems to say that their non US based "Business Relationship Managers" can open a US account on behalf of a foreign corporation without a TIN. They're not explicit about this but strongly suggest this is possible.

So if anyone can clarify whether this will work or the problems we would face, I'd greatly appreciate it. By the way, no one is trying to avoid legitimate US taxes. The owners of the company are not US residents nor citizens, company is not a US company and any independent contractors are liable for their own taxes and tax reporting. We're considering opening this account only as a convenience to the US clients.
Tax Business Panama Services Contractors
Posted by Lowtax user on Jun 27, 2012 at 20:46


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Panama has been aprobre legislation in which the US Citizen are imposible to open and account unless that sing the USA Tax Form
Posted by Lowtax User on Jul 02, 2012 at 21:40


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