complex question: moving LLC from Europe to US

[adam747]

Hello all,

I recently moved from The Netherlands to the US. Back home I had a small IT company registered as an LLC. The most simple action would be to shutdown the LLC in Europe and start a new one in the US, however if I move all assets currently in the LLC I would be taxed minimum 25% capital gain which is very high. To avoid this, I want to transfer the assets (five figure amount) as loans to the new US-LLC and eventually cash them in or use it as the starting capital. How does the IRS look into this situation?

If this question is too specific, can you guys at least refer me to someone specailized in these cases?

Thanks a lot!

Adam

[Freelancier]

Since the issue is with the taxes in your home country, I recommend finding an accountant there who can help you. A US-based accountant who knows Netherlands tax law will be harder to find than just finding one back in your home country and working through the specifics with him/her. The IRS isn't an issue at this point, since you own the LLC, so basically you own the assets of the LLC anyway. Unless there are more members to the LLC, in which case, it's more complicated anyway.