Does anyone have experience of the following company structure for a shopify store that sells primarily to the US? Having a UK holding company (where I am based) and a US subsidiary LLC that actually sells in the US. The US LLC would be transparent for US income tax because it is operated outside the US, but how do you deal with the UK tax as HMRC treats US LLCs as companies? Would you need to register US LLC as a foreign company in the UK?
There are a lot of moving parts with this one. On the UK side, I would recommend you consult with https://www.avaskaccounting.co.uk/ in regards to paying VAT taxes as a foreign LLC. Separately, the US LLC will have form 5472 https://www.irs.gov/pub/irs-pdf/f5472.pdf required each year, and it has a big fine if late now $25K so make sure you get with a CPA to file it on time. Hong Kong is an issue if the entity has effectively connected income in the US. or not. This is where a Tax attorney would come into play. There is no US tax treaty with Hong Kong.