Panama

In Panama there are two main types of company formation:

Panama Anonymous Bearer Share Corporation -- Panama is far more secure than the Bahamas when it comes to bank secrecy.  The Bahamas, in the year 2000, basically removed banking secrecy because of pressure from the USA.  Panama on the other hand has strong banking secrecy both in the law books and in practice.  Panama strongest company privacy wise is the Panama bearer share corporation which  many industry experts say is stronger than the old swiss numbered bank accounts.  Panama purposely offeres this type of corporation for the security minded business person / investor.  It provides protection for those who are being persecuted much in the same way the Switzerland numbered account did in the second world war.

Panama Corporation -- Panama Foundation owned Company --  A Panama foundation is not legally owned by anyone.  A foundation is a self owned entity.  This makes it an ideal vehicle to own a Panama corporation.  It carries the legitimacy of a corporation that is owned (bearer share corporations can sometimes be looked at suspciously when they are challenged in court), while a corporation owned by a foundation provides a clear answer to "who owns this corporation", which eventually comes up in an asset protection lawsuit case.  Legal proceeding stop when they hit a foundation because it is a respected financial entity that nobody can own.  To get assets out of a Panama foundation is legally speaking, next to impossible.  

Bahamas 

Companies incorporated under the Companies Act 1992 are divided into two main types, public and private. Private companies are limited by either shares or guarantee.

For foreigners, here are different kinds of companies you can choose from when incorporating in the Bahamas or Panama:

Bahamas Foreign Company -- Foreign companies can operate in the Bahamas with a very minimal fuss. Once its local presence starts to qualify as an 'undertaking' in the Companies Act 1992, it is required to register with the Register-General. Once registered, the entity is the equivalent of a Bahamian incorporated company and must follow the same rules.

Bahamas IBC (International Business Company) -- An IBC needs only a director, individual or corporate, and two subscribers, all of any nationality, to form one. Meetings can be through electronic means. Income, capital gains, or corporate taxes are not required to be paid by its shareholders. The IBC doesn't have to pay tax or estate duties for twenty years after its incorporation, nor is it required to keep accounts. If these are kept, there is no requirement to audit them. Legislation also protects the assets of an IBC from actions originating from outside the Bahamas. The only documents on public record are the Memorandum and Articles of Association.

Bahamas Limited Duration Company -- The IBC (Amendment) Act of 1994 introduced this form of company, which is identical to the IBC but with a limited lifespan of 30 years. This move was made to cater to a certain class of US investors. In the US, it is known as a Limited Liability Company.

Bahamas Exempted Limited Partnership -- The ELP is an IBC, only it is in a partnership form. One partner (general) is invested with unlimited liability, while limited partners cannot be involved with management. One of the general partners should reside in the Bahamas, or else the company should be formed under the IBC Act 1989 or the Companies Act of 1992.

Bahamas Trust -- Under Bahamian Law, trusts are considered an agreement between private parties. Thus, they need no registering, and as long as they don't hold Bahamian real estate, they pay no taxes. They can be administered by a 'protector of trust.'