Yes, you have read this right: I would like to maximize the taxes paid by a US corporation to make sure that its income tax rate is > 25%.
This is a prerequisite to avoid the profits of the US corporation of being taxed at its shareholder level (double taxation and other issues) Controlled foreign corporation (CFC) rules.
The shareholders are European citizens and would incur additional taxes if the US corporation would be considered to be in a low-tax country for which the threshold is 25% income tax paid.
The main business of the US corporation is investing in stocks which generate capital gains, interest and dividend income.
This was no problem before President Trump reduced the federal corporate tax to 21% but this has become a challenge for non-US controlling shareholders of US corporations. However, this can be remedied if taxes paid by the US corporation are >25%. The corporation has not been founded.
Which strategies would you recommend to make sure that taxes paid are >25%?
What type of corporation (C Corp, S Corp, etc) would you recommend to achieve this goal?
Which US states would you recommend the corporation to be headquartered? (My preference would be Delaware)