Unfortunately because it is not taxed at the personal level, it does not need to stay out of the country and makes it very easy to bring back in the country. This may also depend on the financial institutions and regulation over reporting of large wires, but there are still ways around it. My point was that they can get around these laws so easily due to it being taxed at the corp level and still argue its not avoidance.
No, you misunderstand. It's not enough to satisfy the "form" required of tax law--you must also satisfy a test of "substance." France would pierce through the transaction and treat the "management fee" as a French salary (which, in substance, it is) and haul the taxpayer off to jail for evading taxes.
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Unfortunately because it is not taxed at the personal level, it does not need to stay out of the country and makes it very easy to bring back in the country. This may also depend on the financial institutions and regulation over reporting of large wires, but there are still ways around it. My point was that they can get around these laws so easily due to it being taxed at the corp level and still argue its not avoidance.
No, you misunderstand. It's not enough to satisfy the "form" required of tax law--you must also satisfy a test of "substance." France would pierce through the transaction and treat the "management fee" as a French salary (which, in substance, it is) and haul the taxpayer off to jail for evading taxes.