The project included:

• СAssisting the client in disclosing foreign assets during the so-called “capital amnesty,” as well as in complying with the requirements of Russian legislation on CFCs;
• Coordinating the liquidation of foreign companies (termination of structures) controlled by the client, including interaction with service providers, liquidators, etc.;
• Assisting in application of tax exemption with respect to income from liquidation of CFCs (so-called “tax-free liquidation”);
• Advising on application of Russian double taxation treaties and assistance with implementation of so-called “pass-through taxation”.

As a result of the project, the corporate structure of the client’s business was considerably simplified. The client obtained a number of significant assets in personal ownership, as well as the opportunity to apply “pass-through taxation” with respect to dividends received from the client’s Russian business.

Legal optimization of the corporate structure of the clients – spouses, citizens and tax residents of Russia, who own Russian manufacturing and trading businesses through a group of nominal owners and companies (Cyprus, BVI, Belize, Montenegro).

The project included:

• Assisting clients in disclosing foreign assets during the so-called “capital amnesty” and in complying with Russian CFC legislation;
• Analyzing the tax, currency and other legal consequences of changes in the corporate structure of a business.

Creation of a private trust company (PTC) in the Bahamas to hold the assets of a high net worth Russian businessman on the Forbes list, a comprehensive structuring of his business and personal assets.

The project included:

• Creation of a purpose trust and two private trust companies in the Bahamas to hold the family’s business assets and personal assets.
• Working with an English law firm to develop the private trust company (PTC) trust and corporate documents, including the drafting of trust declarations, letters of wishes, management rules, rules of appointment of trustee and beneficiaries, protectors and subsequent protectors.
• Advising on the transfer of the client’s assets (shares / participatory interests in Russian companies) to PTC management.
• Preparing an opinion on the practical benefits of a structure that ensured continuity in the transfer of control over the client’s assets to its family members and the safeguarding of assets from the standpoint of hostile takeover attempts.