Good question. You've got a few options, depending on your current level of mess and trusts in Australia.
The easiest/cheapest way is a flip up from an AU Pty Ltd to a US C-Corp. You get CGT exemption if you have the same ownership on both sides. The US doesn't have trusts though (or so I think), so your flip up options are more challenging if not closed to you entirely. The next best bet is to create a new, clean corporate structure in the US. Your new US company can either then acquire your AU company (which might be held by your trust or other complicated AU shareholding structure), or you can transfer or licence your IP from the AU company to the US company. Licencing will trigger a CGT event and you'll pay tax on that in the short term, or you can do licencing and deal with the transfer pricing issues forever. I'm told there is a third option. If you have a lot of money in an exit, there are mysterious tricks you can do. I know a mate who did it, spent about $400K on games and saved >$5M in CGT if he'd just been a mug. But, he'd sold his company, so he had the $ to spend on the big advice. G On Wed, Oct 12, 2011 at 16:43, Jeromy Evans <jeromyev...@gmail.com> wrote: > > On Oct 12, 4:13 am, Geoff McQueen <geoff.mcqu...@hiivesystems.com> > wrote: > > Another dimension to Patrick's comment: if you're planning on moving to > the > > US to raise venture money for your business, also be aware that... > > Geoff/Patrick/Others, when you took your businesses to the US did you > shutdown the Australian entity, take on international shareholders in > the Aus entity or setup in the US and maintain both entities? Is that > transition process described anywhere? > (sorry, this may deserve a new thread but the context in the previous > posts is important; setting up complex structures for Aus when it's > likely only a temporary investment vehicle anyway) > > -- > You received this message because you are subscribed to the Silicon Beach > Australia mailing list. Vist http://siliconbeachaustralia.org for more > > Forum rules > 1) No lurkers! It is expected that you introduce yourself. > 2) No jobs postings. You can use http://siliconbeachaustralia.org/jobs > > > To post to this group, send email to > silicon-beach-australia@googlegroups.com > To unsubscribe from this group, send email to > silicon-beach-australia+unsubscr...@googlegroups.com > For more options, visit this group at > http://groups.google.com/group/silicon-beach-australia?hl=en?hl=en > -- Geoff McQueen Founder & CEO Hiive Systems Phone: 1.877.425.7315 (US) - 1800 2 44483 (AU) Cell/Mobile: 650.450.4384 (US) - 0414.678.466 (AU) -- You received this message because you are subscribed to the Silicon Beach Australia mailing list. Vist http://siliconbeachaustralia.org for more Forum rules 1) No lurkers! It is expected that you introduce yourself. 2) No jobs postings. You can use http://siliconbeachaustralia.org/jobs To post to this group, send email to silicon-beach-australia@googlegroups.com To unsubscribe from this group, send email to silicon-beach-australia+unsubscr...@googlegroups.com For more options, visit this group at http://groups.google.com/group/silicon-beach-australia?hl=en?hl=en
