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Using Banks and Bank Accounts/Where to open a bank account for a BVI company


Hello Alexander

I own a BVI company - registered through a Share trust for which I own the shares - and provide offshore software services to US companies. As far as I understand, this is Foreign Source Income, right?

I want to open a business bank account to receive payments for our services - each payment will be backed by an invoice to the customer.

My question is if I can open an account in a US bank - to make things easier to my US customers - or that is not possible, and I should just do my banking outside the US.

Thanks in advance

It is possible to do this. The best way to do it would be to establish a US LLC which will be owned solely by the BVI company. In this way you will avoid having to even declare any income or file any taxes in the USA.

The reason for this is that a US LLC is considered a "disregarded entity" by the US tax authorities, and if it is owned entirely by a non-US individual or entity, is considered a simply the same as the owners. In this case it will be the BVI company.

Now if the US LLC is used solely to receive funds for goods and/or services from outside the US, non-US Source Income, simply having a bank account in the US will not turn it into US Source Income. In fact the IRS has special rules for this, and they encourage foreign companies to do business in the USA in just this way. It is described as a "marketing office" by the IRS.

For more information see:

Please feel free to contact me if you would like to further discuss this.

Using Banks and Bank Accounts

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Alexander J. Hay


I am a U.S. lawyer with offices in Houston, Texas and in Belize. I can answer questions on U.S. Immigration, U.S. corporate law, and Offshore Tax and Asset Planning.


I am a U.S. attorney with offices in the United States and Belize. I have experience helping to protect assets, reduce taxes, and improve investment performance by utilizing global investment techniques.

Harvard University, A.B. degree; University of Houston Law Center, J.D. Degree; Fulbright Scholar

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