Advising on asset ownership structure and income generation by individuals
change in the procedure for payment of income or restructuring of assets ownership in connection with changes in the current situation (merger/termination of automatic exchange of financial information, conclusion/termination of a double tax treaty, etc.);
financing of controlled foreign companies (CFCs) by private individuals, taking into account restrictions imposed by currency laws and special economic measures in connection with the hostile actions of the US and foreign countries and international organizations that have joined it;
application of preferential terms stipulated by tax laws to transfer assets into the ownership of individuals;
application of Russian laws on CFC taxation, including analysis of CFC financial statements;
diagnostic assessment of the tax burden and restrictions on the payment of income to beneficiaries who are individuals, in terms of tax and currency laws and special economic measures;
tax implications of investments in real estate, securities, cryptocurrency assets, etc.;
issues of international taxation and the application of double tax treaties.
Advising on transactions involving the sale/acquisition of assets by a private individual
consideration of transaction structuring options in terms of tax implications and restrictions imposed by currency laws and special economic measures;
preparation of protection documents/wording of the transaction contract in terms of tax implications and restrictions imposed by currency laws and special economic measures;
support in declaring transaction income.
Voluntary declaration of assets and foreign accounts
diagnostic assessment of compliance with the requirements of tax and currency laws and special economic measures;
supporting participation in the campaign on voluntary declaration of assets and foreign accounts and advising on the subsequent disposal of assets declared in special tax returns;
analysis of special tax returns submitted as part of previous stages of voluntary declaration of assets and foreign accounts (the so-called “amnesty of capital”) for the purpose of protection against current claims of the tax authorities.
Reporting and dealings with tax authorities
preparation of tax reporting of individuals in Russia and abroad, including notifications of participation in foreign entities and CFCs;
dealing with the tax authorities of the Russian Federation/foreign tax authorities in respect of filed tax returns, including justification of offsetting taxes paid in foreign countries and support during desk and field tax audits/tax control measures of foreign tax authorities;
supporting individuals during pre-audit measures to monitor compliance with the requirements of the tax and currency laws of the Russian Federation (in particular, as a result of the receipt by the tax authorities of information as part of the automatic exchange of financial information);
reconciliation with the tax authorities on tax settlements, receipt of tax deductions and various statements and documents (on the absence of taxes payable, confirmation of the status of a resident for the purposes of a double tax treaty, etc.);
preparation and submission to the Russian tax authorities of individuals’ notices on the opening, changing details and closing of accounts with foreign banks and other financial institutions, as well as reporting on these accounts.
Family capital and inheritance
advising on taxation issues (restrictions imposed by currency laws and special economic measures, if applicable) in Russia and abroad related to donation, division of property and inheritance;
analysis of options for structuring the ownership of assets for the purposes of financing the expenses of family members and inheritance;
Immigration and residency
analysis of the tax and residence permit regimes (outside the Russian Federation and for foreign citizens in the Russian Federation);
comparative analysis of jurisdictions based on agreed criteria;
support in obtaining a residence permit or citizenship.
Contact
Please contact us by completing the feedback form at the link below (in the Type of inquiry field, select Request for proposal)