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He unquestionably still owes taxes on that money.



.. when that money is repatriated to the U.S. (e.g. upon paying himself).


My understanding is that this is mostly correct. Money held by the company probably isn't considered his and probably isn't taxed; money he pays himself certainly is (whether it goes to an account nominally in the US or not, and whether it is denominated in bitcoins or not). Obviously he should be talking to an accountant and/or tax attorney and making sure that's all straight.




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