It's around 55–60% of immigrants who come from Spanish-speaking countries.
Also, this uses official numbers, which reflect a larger Spanish speaking share than there is in reality (as people from Spanish-speaking countries have more straightforward visa processes).
So the real percentage is probably much lower (as there are a lot of undocumented migrants. 1.2 million applied for "legalization").
Company will end up as tax resident from the country where it is managed & controlled .
If there is an DTA the tie breaker rule applies and the country from where it is managed & controlled gets the right to tax .
Also you get to enjoy bureaucracy+ dual accounting in both countries .
If there is no DTA it can lead to double taxation .
And if you don't have a fixed place of management/business+ tax residency (basically nomading) a US LLC disregarded for tax purposes is a much better fit .
You need to demonstrate real substance (such as actually managing/working from there e.g in your case Leipzig ) .
If you can't prove real substance they will just shift it back to berlin and you could be also held liable for tax evasion (if there is a lower gewerbehebel )
What should the US LLC do ?
It will end up being treated like a GMBH in Germany (keyword : Typenvergleich ) and you will have to do all the bureaucracy in the us + Germany and end up paying the same taxes
This will most likely result in Permanent establishment (PE) in Germany (e.g due to fixed place of business).
That means Germany will tax the company anything which is attributable to the German guy.
Yes , but cfc rules are mostly targeted against passive income and exclude active companies.
They wouldn't matter in that case anyway as he would shift the tax residency to Germany by managing & controlling the company from Germany.
Don't incorporate somewhere else it will only lead to disaster.
The company will end up being German tax resident anyways due to management and control being in Germany as you live in Germany .
Then you have to be compliant in 2 jurisdictions (file forms/balance sheets in both countries etc..) and worst case you could become subject to double taxation (if there is no agreement).