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Offshore Services: Use Cases
Departing your tax jurisdiction and restructuring and/or movement of non-bankable and/or liquid assets into a tax shelter can be subject to heavy tax obligations, such as departure tax and capital gains tax obligations. Setting up a tax shelter properly means being fully compliant to beginning and ending tax jurisdictions while systematically reducing their tax obligations through a structured tax planning strategy. Hence, a customized solution may help to provide for tax efficiencies, provide privacy, and create a compliant framework with financial accountability, all within a well-regulated and structured environment.
Note that these use cases are not limited to the following case studies, and are meant to help patriarchs understand what possible scenarios may exist. We require a minimum of USD$5million in liquid assets prior to setting up an investment vehicle or asset holding solution with our multi-family office platform.
Existing Shareholding
Client: Business family owns operating company(s), cash, real estate, and other assets onshore that pays substantial annual dividend, subject to significant inheritance or capital gains tax, or costly ongoing restructuring due to changing laws by a changing government.
Objectives: Maintain Privacy, Asset Protection, achieve Tax Efficiency, and be fully Compliant with CRS reporting and Tax laws.
Solution: Ownership of operating company was restructured to be held through a Life Insurance-Fund Structure.
New Equity Share Subscription
Client: Business family owns a operating company and wishes to inject equity capital to fund acquisitions of companies located in frontier markets or fund growth of its own operating business(es).
Objectives: Maintain Privacy, achieve Asset Protection and be fully Compliant with CRS reporting and Tax laws.
Solution: Life Insurance-Fund was setup to inject new equity capital through a life insurance fund, which invested in new acquisitions and/or growth of its own principal business(es).
Pre-M&A or Pre-IPO of Operating Company
Client: Entrepreneur setup a company 20 years ago and decided to sell, however did not immediately require the proceeds.
Objectives: Maintain Privacy, achieve Tax Efficiency, and be fully Compliant with CRS reporting and Tax laws.
Solution: Life Insurance-Fund took over the shareholding of the company and executed the sale of the company, cash proceeds are held within in the fund and allocated to a Private Bank where capital gains & income accrue on a tax deferred basis.
Additional: Entrepreneur withdraws a small amount annually, which is only taxed when received.
Back-to-Back Debt Financing
Client: Business family wishes to provide a substantial Corporate Loan ofinance business operations and investments of an operating business
Objectives: Maintain Privacy, and be fully Compliant with CRS reporting and Tax laws.
Solution: Life Insurance-Fund was setup to provide a Corporate Loan to operating company.
Additional: Interest paid from the operating company goes back into the Life Insurance-Fund and is accumulated as cash.
Incubation of Emerging Fund Manager
Client: An emerging fund manager that has a minimum commitment of USD $10 million in liquid assets from investors.
Objectives: Fund manager that wishes to operate the fund under the multi-family office's license.
Solution: Set up a fund under the umbrella of the multi-family office
Additional: Fund manager focuses on the active management of assets of the fund, and the multi-family office provides back-office support.
Transactions which we also are engaged in with the use of offshore special investment vehicles include private equity buyouts, M&A transactions, shareholder buyouts, horizontal and vertical integrations, joint ventures, asset or department divestment, corporate re-structuring, and intellectual property transactions and management.
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