International Tax Expert Needed: US LLC + Malta Structure (Fiscal Unit) – E-commerce ($10M Rev)

We are a rapidly scaling e-commerce business (Dropshipping/Brand model) operating via a US LLC, currently generating significant revenue (projected $10M/year). I am an Italian citizen, tax resident in Malta under the Non-Dom program. I am looking for a high-level International Tax Advisor or CPA with proven experience in Cross-border taxation (USA-Malta) to assist with a corporate restructuring. The Current Situation: • Owner: Malta Tax Resident (Non-Dom status). • Current Vehicle: US LLC (Disregarded Entity). • Business Model: E-commerce selling to the US market (goods shipped from China). No US ECI. The Goal: We intend to transition from a personal ownership structure to a corporate structure in Malta to manage cash flow and investments efficiently. Proposed Structure: Cyprus Holding + Malta Trading Ltd (owning the US LLC). Scope of Work & Key Questions to Solve: We need an expert validation on the following strategy: 1. Fiscal Unit vs. Tax Refund: Validating the use of the Malta Consolidated Group (Fiscal Unit) to pay the 5% effective tax rate immediately, avoiding the cash-flow trap of paying 35% and waiting for the 6/7 refund. 2. Holding Location: Confirming the feasibility of a Cyprus Holding for a Malta Resident. We need to analyze the trade-off between gaining immediate corporate liquidity (Fiscal Unit) vs. losing the personal Remittance Basis on dividends. 3. US Compliance: Handling the transition of the US LLC from individual ownership to Malta Trading ownership (Forms 5472, 8832, etc.) and Transfer Pricing requirements. 4. Banking & Investments: Structuring the Holding to access Tier-1 banking (e.g., Swiss banks) for ETF/Stock investments. Requirements: • Deep knowledge of Malta Corporate Tax Law (specifically Consolidated Group Rules/Fiscal Unit). • Deep knowledge of US Tax Law for Foreign Owners (Disregarded Entities, ECI, Branch Profit Tax). • Experience with E-commerce/Digital businesses. • (Preferred) Experience with Italian clients residing in Malta. To Apply: Please answer the screening questions below. Generic proposals will be ignored. We are looking for a expert strategic partner. Screening Questions (da inserire nelle impostazioni di Upwork): 1. What is your opinion on using a Malta Holding vs. a Foreign Holding (e.g., Cyprus) for a Malta Non-Dom resident who wants to maximize immediate corporate cash flow? 2. Are you familiar with the Malta "Fiscal Unit" (Consolidated Group) rules introduced in 2020? Can you explain the main advantage over the traditional refund system? 3. Have you handled the transfer of a US LLC from a foreign individual to a Malta Company before? Apply tot his job