Q: Offshore LLC and US resident tricky dividends tax question.

A: If only your question were as simple as it appears.

Please realize that the answers I am giving below are generalized answers and I strongly suggest that you use an experienced tax professional to prepare your return (more details about this below).

First, your US tax resident starting date, if based on a Green Card status, depends not only on the date you received your Green Card, but the date you first came to the US after receiving your Green Card. For example, if you received your Green Card in May but did not come to the US until December, the start of your tax residency would begin in December, not in May. You can find more information about this on the IRS web page for Residency Starting and Ending Dates: https://www.irs.gov/individuals/international-taxpayers/residency-starting-and-ending-dates

Now, to the more complicated part of your question: Sole-owner LLC's from the United States and most other countries are eligible for "disregarded entity" classification, which would generally cause the owner to be taxed on the net income generated from the company regardless of whether this income is actually paid to the owner. Public Limited Companies from Belize, however, are not eligible for this status. These companies are taxed by the U.S. as foreign corporations using a Form 5471 which is filed with the U.S.-owner's personal income tax return. Although this shares some similarities with U.S. corporations regarding taxation on dividends distributed, there are also various ways in which income that is not distributed can be taxed to the owners. The tax law does this due to the concern that people would hide money in foreign corporations and seek to avoid U.S. taxes by simply not distributing the money.

A Form 5471, Information Return of U.S. Persons with Respect to Certain Foreign Corporations, is a highly complex tax form that very few tax professionals are experienced in working with, though some claim to be more experienced than they actually are. There are very specific laws and regulations about these returns for foreign corporations and, in many instances, missing or incomplete guidance by the IRS. I highly recommend using a tax professional with a great deal of experience in addressing foreign income and assets. You should look for someone who has prepared more than 1-5 of these but outside of the Big 4 accounting firms or large law firms with large tax divisions, you likely will not find a firm that has done hundreds of them either. Beware, however, that the tax preparation fees for this information return by any actually experienced professional (or team of professionals) are likely to be rather high due both to the amount of work and research to generate the return as well as the knowledge and skill that goes into preparing it correctly.