Projects in the area of deoffshorization changes in the tax legislation of the Russian Federation
- Analysis of existing ownership and financing structures of assets located on the territory of the Russian Federation from the point of view of the application of new Russian deoffshorization initiatives (beneficial owner rules, tax residency and taxation of indirect sale of real estate)
- Developing a "defense position" in relation to such structures and providing recommendations for their modification and transition to target structures more sustainable to the new rules.
- The projects were implemented in relation to numerous structures owning real estate in the Russian Federation, including foreign fund structures
Projects in the area of the Russian CFC rules
- Analysis of tax consequences for controlled foreign companies (CFC) arising at the level of individual shareholders, Russian tax residents
- Analysis of personal ownership structures used for possession of personal financial assets, real estate, air and sea-crafts with regard to application of the Russian CFC rules
- Analysis of corporate structures holding and financing business assets with regard to application of the Russian CFC rules
- Preparation of notifications of participation in foreign companies, assistance in preparing notification of participation in the CFC and calculation of the profit of the CFC. Comments on the methodology for recognizing the share in the CFC
Projects in the area of private assets holding and wealth management structuring
- Recommendations for the establishment of a foreign structure (not being a legal entity) recognized as an uncontrolled structure in terms of application of the Russian CFC rules used to manage personal assets and address inheritance issues