• We will develop a design of the ownership structure for you in accordance with the requirements of Law no. 361, analyze potential risks and threats in the structure following the taxation rules for controlled foreign companies, and provide relevant recommendations.
• We will evaluate the if it is feasible to liquidate your controlled foreign company, including a "tax-free" one, and assess the tax implications for the controlling person (depending on the terms of liquidation and assets owned by the controlled foreign company).
• We will carry out CFC - diagnostics: identify the controlling persons, establish the need to report on CFC, estimate the expected taxes to be paid by the controlling person from all operating CFC, provide recommendations on business structure and model improvement.

For owners and controlling persons of international structures (legal entities or organizations with no status of a legal entity, like trusts or funds).