If you ask the typical American tax administrator to name a notorious tax haven they would probably name the Cayman Islands or the British Virgin Islands or some other small nation that makes a disproportionate amount of its budget by accommodating international tax structures. Ask the same question of a European tax administrator and the answer will likely be Delaware or Nevada.

The ease and rapidity with which a U.S. Limited Liability Company (LLC) can be formed in these jurisdictions is a matter of wonder to many Europeans. More ominous, in their eyes, is the fact that the ownership of U.S. LLCS is not a matter of public record. Indeed, even the states in which the entities are formed generally do not have that information. An LLC can be established by an “incorporator,” who can be a lawyer, accountant, paralegal, or other person who has no interest in the company and no obligation to disclose the owners.

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