TAXATION

As described above, a correctly structured Delaware LLC which has no US source income or income effectively connected with the conduct of a US trade or business would not be subject to any form of US tax on income.

MEMBERS

An LLC is required to have only one member but it is thought that tax free status will only be applicable to LLC's which have two or more members.  Members are the equivalent of shareholders in a normal corporation but hold "units" rather than shares.  The details of the incorporating members appear on the public file but, in our suggested structure, the members would be TCI companies so anonymity would be retained.  Changes in members do not have to be reported.

MANAGERS

It is normal for one or more managers to be appointed whose responsibilities and functions would be similar to the directors of a normal company.  Alternatively, the members themselves may elect to carry out  the administration of the company themselves in a similar manner in which the partners of a partnership conduct their affairs.  Details of the managers do not appear on the public file.

ANNUAL REPORTING

A simple franchise tax report must be completed each year but this does not give any details about the structure of the LLC.  Provided the LLC conducts no US business and receives no US source income neither the LLC nor its foreign members would be required to file US tax returns.

TIMESCALE

Incorporation can be achieved within 48 hours.  However it does take approximately 7 days for documents to arrive from Delaware.  We do not generally keep ready-made companies in stock.

RESTRICTIONS
ON NAME AND
ACTIVITY

The name must end with the words "Limited Liability Company" or "LLC".  The following words, and associated activities, cannot be used - bank, trust, university, college or school.

LOCAL
REQUIREMENTS

As a matter of local company law the company MUST maintain a registered office address within Delaware and must also appoint a Delaware resident as registered agent.  We would generally provide these services as part of the domiciliary service fee.