Stani Korostelev

mid-shore and offshore companies with banking accounts @thepointlegal nothing ventured, nothing gained

[Stani Korostelev @AmusingVentures]

@fin465 plus, adding a payment/neobank functionality to your platform has never been easier

[Stani Korostelev @AmusingVentures]

@AndrewStarts @moneyfetishist Haha, I mean, it's quite a common question for founders in Europe when they fundraise in the US and open a C-Corp, but keeping the center of interest in Europe. So, paying taxes in Germany is OK, I just wanted to understand how it works - you file here and there?

[Stani Korostelev @AmusingVentures]

while the growth of IBCs registered in Seychelles is slowing down compared to mid 2010s, the number of brokers licensed there has tripled in the last 5 years. we're talking eToro, Exness, and a bunch of other names you'd recognize.

the reason is simple: unlimited leverage.

most jurisdictions cap leverage at 1:30 or 1:50 for retail clients. Seychelles doesn't. if you're a broker targeting non EU, non US clients, that's the whole pitch.

Seychelles IBCs aren't dying. the use case just shifted from generic offshore holding to regulated brokerage.

[Stani Korostelev @AmusingVentures]

@Mondeju1 @TheJerzWay We all know the answer, I think.

[Stani Korostelev @AmusingVentures]

Carta just bought Avantia Law. everyone's framing this as "cap table company enters legal." but Avantia served 200+ asset managers, not startups.

the actual M&A logic: Carta has $220B+ AUM under fund admin and 9,000 funds. they bought legal for fund administration clients, not for the 50,000 companies on the cap table side.

fund admin + legal is the bundle. corporate legal for startups was never the play here.

what this means for small firms like ours at @thepointlegal: Carta is coming for the fund admin legal wallet, not the startup legal wallet. if you do startup legal, you're fine for now. if you do fund formation and admin, start paying attention.

[Stani Korostelev @AmusingVentures]

@defyneric You also have to pay upfront to charter companies if you sell group tours / trips which is another nightmare for liquidity management.
And insurance as well.

[Stani Korostelev @AmusingVentures]

a lot of hype about AI agents executing transactions autonomously and buying services, booking things, trading with other agents.

but nobody is talking about VAT, GST and other cross-border taxes

when Agent A in Ireland buys a service from Agent B in Singapore, which jurisdiction's VAT applies? where is the place of supply? who is the taxable person? the agent has no tax residency. it has no VAT registration number.

current VAT frameworks assume a human or a registered entity on both sides of the transaction. agent-to-agent breaks that assumption, and it gets worse at scale with thousands of micro-transactions per minute across dozens of jurisdictions. no invoice. no tax point. no clear chain of liability.

the companies building agent infrastructure are shipping product. the tax infrastructure for what they're building doesn't exist yet.

[Stani Korostelev @AmusingVentures]

good breakdown by @stacy_muur on crypto cards (Tria vs EtherFi vs KAST vs neobanks).

one thing people miss: every single one of these runs on traditional banking rails. someone holds a BIN sponsor relationship. someone has a card issuer license. someone has a deal with Visa or Mastercard.

the crypto part is the frontend. underneath it's the same compliance stack: KYC, AML, transaction monitoring, sanctions screening.

when a project says "spend crypto anywhere Visa is accepted" they mean "we found a licensed partner willing to convert your on-chain assets to fiat at the point of sale."

that partner can disappear. I had money on Cryptopay. they went down, and years later I still can't recover it. the card worked perfectly until the day it didn't.

if you're building in this space, the product is the easy part. the banking partnership is where projects die.

[Stani Korostelev @AmusingVentures]

@mop_j9 Interesting, thx for sharing! Probably you are right that calling it completely useless is mistake, but I wrote such a strong opinion on it because if it doesn’t work on mainstream exchanges, then the value drops significantly.
Which cards have you tried with it so far?

[Stani Korostelev @AmusingVentures]

a client asked me on a call last week about the Palau digital residency. saw an ad on X, wanted to know if the $250 card helps with international business.

short answer: no.

the pitch is you buy a digital ID and use it for KYC on crypto exchanges instead of your real passport. sounds clever until you realize most serious exchanges stopped accepting it after US regulatory pressure.

Palau is part of COFA (Compact of Free Association with the US). the US provides defense, funding, Palauans can live in the US unrestricted. which means Palau can't exactly go rogue on sovereignty programs without consequences.

@recouso explained this well. the Palau e-residency gives you roughly the same privileges as a gym membership. you get a card with your name on it. no tax benefits. no banking access. no help with corporate structuring. no substance for your holding company.

if you're building a real international business in a regulated or semi-regulated space, a $250 digital ID card is not going to solve your compliance problems.

don't waste money on shortcuts that don't shortcut anything.

[Stani Korostelev @AmusingVentures]

the best operational decision I've seen founders make has nothing to do with jurisdiction selection or tax rates.

it's banking.

specifically: putting your holding company and operating companies with the same bank or EMI.

most founders open accounts wherever they can get approved. holdco with one bank in Singapore, opco with another in the UK, a third somewhere in Europe. three banks, three compliance teams, three sets of questions every time you move money between your own entities.

intragroup transfers between different banks are a nightmare. each bank treats it like an external payment. they want invoices, transfer pricing docs, board resolutions. a simple dividend from opco to holdco takes two weeks and four emails.

same bank? the compliance team already sees both entities. they understand the group structure. intragroup moves clear in hours. one relationship manager who knows the whole picture instead of three who each see a fragment.

nobody posts about this. but I've seen this single decision cut admin overhead by 70% and save founders from banking delays that kill deals.

pick your bank before you pick your second jurisdiction. seriously.

[Stani Korostelev @AmusingVentures]

@pitdesi This one is often quite crowded, but still great experience. Try smth like Kochelsee or Königstherme next time you are around.

Also, O2 Surfing is a great spot to kill time close to the airport.

[Stani Korostelev @AmusingVentures]

Hong Kong doesn't tax foreign-sourced profits. Sounds like a free pass, but IRD will test you on it.

The rule is territorial: only profits "arising in or derived from" Hong Kong are taxable. The catch is proving where the profit-generating activities actually happen. IRD calls this CIGA, core income-generating activities.

They look at where contracts are negotiated and signed, where services are delivered, where key decisions are made. If your directors sit in HK and run things from there, IRD treats the income as HK-sourced. Doesn't matter if every client is in London or Dubai.

So the design problem: you want the HK company for banking, reputation, Asia presence. But you need the actual work that produces revenue to happen outside HK.

In practice: foreign-based staff do the delivery. Contract signings happen in a foreign office. Email, call logs, travel records support the offshore pattern. HK becomes a registration and treasury location, not where the money is made.

Most people skip this. They incorporate in HK, run everything from HK, file for offshore profits exemption and wonder why IRD pushes back. The exemption is real. You have to build the structure to match it.

[Stani Korostelev @AmusingVentures]

@mert wagmi

[Stani Korostelev @AmusingVentures]

@Adrien_B_A Some people notice nothing but shit, even in the alpine meadows.

[Stani Korostelev @AmusingVentures]

founders outside the US ask me "can I even set up a US LLC from abroad?"

yes. and in a lot of cases you should.

BVI holding + US LLC is one of the most common setups I build. the BVI holds equity, the US LLC operates or holds IP depending on the model. if the LLC is structured as a disregarded entity, the US doesn't tax it at the federal level. profits pass through to the BVI parent.

sounds clean. here's what people get wrong.

the LLC still needs an EIN. still needs a registered agent. still needs a US bank account, and getting that bank account as a foreign-owned entity is the part nobody warns you about. compliance officers want to understand why a BVI company owns a Wyoming LLC with no US employees.

and your home country still matters. if you're tax resident in Germany or France, they'll look through the structure and tax you on worldwide income anyway. the LLC doesn't make you invisible.

it works. but only when the full chain is designed together: holding jurisdiction, operating entity, banking, and your personal residency. skip one link and the whole thing falls apart.

[Stani Korostelev @AmusingVentures]

I've been bootstrapping AI-assisted legal / tax consulting from scratch for >1 year to figure out where AI makes a difference in professional services. I found a niche of offshore/non-US corporate service providers (CSP) that is not on the radar for US founders, yet has great unit economics, and now building an AI-first CSP.

[Stani Korostelev @AmusingVentures]

@vitaliidodonov MRR