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Everything else we've written.

Residency10 min read

The 183-day rule is not a rule

Stay under 183 days and you're fine — the most confidently repeated wrong thing in this industry. In most countries the day count is one input among four, and in several it isn't even the first one checked.

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Tax8 min read

What a non-resident with a US LLC actually owes the IRS

The most expensive misunderstanding in this niche: a foreign-owned single-member LLC that owes zero tax still has a mandatory annual federal filing, and missing it starts at $25,000. Here is the complete obligation list.

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Structure7 min read

Your company's second year costs more than its first

Everyone quotes you the formation fee. Nobody quotes you year two, which is when the registered agent renews, the franchise tax lands, the federal information return falls due, and the $99 special stops being $99.

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Banking8 min read

Opening a US bank account as a non-resident, honestly

Not a list of the ten best accounts. A decision tree — because the thing that decides your outcome is your passport and your customer base, not which brand has the nicest dashboard.

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Residency8 min read

Exit taxes: what it costs to leave

Leaving is treated as selling. A dozen countries will tax you on gains you have not received, on the day you stop being resident — and the US version, which everyone talks about, is the one least likely to apply to you.

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Structure8 min read

CFC rules will find your offshore company

The company is registered in a zero-tax jurisdiction. You are not. There are three separate doctrines that close that gap, and for a solo founder the one that closes it fastest is not the one everyone worries about.

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Structure6 min read

When to stop being a sole proprietor

"Form an LLC to protect yourself" is sold to people who have nothing to protect and no exposure to protect it from. Here are the five moments when it genuinely becomes the wrong call to stay unincorporated.

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Banking7 min read

Payment processors freeze accounts. Plan for it.

A freeze is not a punishment and it is rarely a mistake. It is an acquirer deciding it is carrying more risk than it agreed to. Understanding whose risk it actually is tells you exactly what to do about it.

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Residency7 min read

Territorial tax countries, ranked by whether you'd live there

The tax rate is the easiest thing to find and the least useful thing to compare. What separates these places is what residence costs to get, what it costs to keep, and whether the rule you moved for survives the decade.

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Residency8 min read

US visa routes for founders, and the entity each one needs

Owning a US company gives you no right to be in the US. Six routes do, each with a different gate — and each quietly assuming a particular entity, ownership split and employment history that you either have or you don't.

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Structure7 min read

Dissolving a US LLC without leaving a tail

The company stopped trading eighteen months ago, so it is closed. It is not. It is accruing state fees, missing a federal information return with a $25,000 penalty, and quietly building a problem you will meet at the border of your next company.

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Tax7 min read

Treaty shopping doesn't work, and what does

The structure that worked in 2014 fails in 2026, and it fails on a test so broadly drafted that arguing about it is usually pointless. The good news is that most founders are trying to solve a withholding problem they do not actually have.

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Structure6 min read

Virtual addresses: what they're accepted for and what they aren't

A founder abroad needs a US address and buys one, then discovers it works for the state filing, half-works for the IRS, and gets the bank application declined. These are four separate problems sold as one product.

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Tax7 min read

Paying international contractors without creating a permanent establishment

The salesperson you engaged in Madrid closes deals from Madrid. Somewhere around the fourth one, your company acquired a Spanish filing obligation — and nobody involved did anything wrong or unusual.

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Structure6 min read

Holding company structures, and when a founder is too small for one

A second company doubles your filings, your bank onboarding and your substance obligations, and protects nothing you were actually exposed to. There are six cases where it is right. Most founders asking about it are in none of them.

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Residency6 min read

Tie-breaker rules: what happens when two countries both claim you

Two countries can both be right about you at the same time. If there is a treaty, a four-step sequence decides which one wins. If there isn't, nothing decides it, and you pay both.

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Residency6 min read

Becoming tax resident somewhere new, properly

Almost everything written about relocation is about leaving. Arriving has its own checklist, and the founders who skip it discover the gap two years later, when someone asks for a certificate they never applied for.

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Residency6 min read

Social security across borders: the bill a tax treaty doesn't cover

You checked the tax treaty. It says nothing about social security, because social security is governed by an entirely different set of agreements — and where none exists, two countries can both charge you in full.

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Structure6 min read

What diligence actually asks for, and why you can't produce it

Nobody loses a deal because the company was structured badly. They lose value because the documents proving it was structured at all were never signed, never filed, or live in a departed co-founder's account.

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Tax6 min read

FBAR and 8938: the filings American founders discover late

You owed no US tax, so you assumed you owed no US filing. The two are unrelated. The reporting obligations attach to holding foreign accounts and foreign entities at all, and their penalties are assessed per form, not on the tax that was never due.

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Banking6 min read

A US LLC for an OFM agency — and banking that won't drop you

Forming the company is the easy part. Keeping an account open once the payouts start is where most OFM agencies come unstuck — usually because of how the business was described, not what it does.

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Structure8 min read

US LLC vs Dubai vs Hong Kong: which one actually fits

Three structures, three completely different bets. The cheapest to run isn't the cheapest to bank, and the 0% headline usually belongs to somebody else's facts. Here's what each one is genuinely good at.

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