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Personal Holding Mechanisms
Are you facing the need to establish or modify your current holding arrangements due to increasing demands on financial and tax transparency and the adoption of new laws on the identification of business beneficiaries?

ALPINE Tax experts work with all types of instruments from trusts and private foundations to special types of legal entities and will prepare the best solution for your situation on the ownership of personal and business assets, including using a personal holding mechanism.

Holding mechanisms
We have developed the structure of the trust / fund considering the goals and objectives of the client (capital succession, accumulation, investment, predictable inheritance, tax efficiency, asset protection, etc.), including:

- elaboration of tax configuration for Russian tax purposes (CFC / non-CFC) ;

- analysis of jurisdiction, the legislation of which helps to achieve the set goals and objectives (non-enforcement of decisions of foreign courts, protection of assets from claims of third parties, etc.);

- analysis of configuration in terms of foreign legislation ( revocable / irrevocable , discretionary , etc.).

We accompanied the client when choosing a trustee / forming the fund council, and also developed the constituent documents of the structure (trust agreement, charter and rules of the fund, letter of will) and other required documentation.
The client requested for the best way to arrange the transfer of assets from the trust. It was necessary to analyze the possible options for transferring assets from the trust and choose the best one - with the least tax burden.

As part of the project, we: - analyzed the available trust documentation, including a list of assets to be transferred;

- analyzed options for tax consequences for an individual when terminating trusts and receiving property from trusts if an individual is recognized as a tax resident in possible jurisdictions (including in Russia);

- Developed 3 options for obtaining assets from a trust / termination of a trust. Based on the results of the project, an optimal approach, from a tax point of view, was developed for the termination of a trust and the distribution of its assets to beneficiaries.

The work carried out allowed the client to terminate the trust with a minimum tax burden and receive significant assets from it.
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