
Advice to private clients on complex tax and currency issues - about foreign accounts, controlled foreign companies and capital amnesty in Russia in 2022
If you have a personal account or property abroad:
notification of account opening/closing;
opening a new account in a Swiss bank (to place an investment portfolio);
report on the movement of funds on accounts abroad (in banks, brokerage, management and insurance companies);
calculation of personal income tax according to Russian rules;
tax declaration 3-NDFL in Russia (income from investment portfolio, rent, sale of real estate abroad);
advice on tax consequences in Russia and abroad (opportunities to reduce the burden under Double Taxation Treaties, offset tax refunds paid abroad);
planning for the transfer of personal assets to the next generation (taking into account tax and other consequences in Russia and abroad);
"packaging" of personal assets in foreign companies, trusts / family funds, insurance products (investment life insurance);
tax planning of moving abroad (immigration for investment, residence permit, permanent residence), as well as returning to Russia after living abroad;
advising on currency restrictions on transactions on personal accounts abroad (taking into account the jurisdiction of the account, as well as the content of planned and conducted transactions);
immigration for investment (“second” passport or residence permit in Europe).
If you are a shareholder of a foreign company:
notice of participation / termination of participation in the company;
notification of a Controlled Foreign Company (CFC);
preparation of financial statements (with or without audit) based on the results of CFC activities
adjustment of financial statements for personal income tax purposes based on CFC profits in Russia;
tax planning and advising on the personal income tax burden in relation to CFC profits (taking into account planned dividend payments, CFC tax payments abroad, including at the source in Russia);
tax consulting on the choice of a CFC profit calculation option for personal income tax purposes in Russia (IFRS, US GAAP or Chapter 25 of the Tax Code of the Russian Federation "Corporate Income Tax");
choice of reporting option for CFCs in Russia (annual financial statements with an audit or a “lump-sum” tax on CFCs) taking into account your situation;
assessment of the need to restructure your companies (liquidation and sale of individual companies, their redomiciliation to Special Administrative Regions - tax "offshores" in Russia), taking into account the tax consequences of CFCs in Russia;
assessment of the risk of a CFC being recognized as a tax resident in Russia (with additional taxes being charged to it as a Russian taxpayer);
creation of new companies in other countries, as well as trusts / family funds / partnerships, opening of insurance products (for transferring personal and investment assets of the beneficiary to them);
advice on tax consequences in Russia and abroad (opportunities to reduce the burden under Double Taxation Treaties, offset tax refunds paid abroad).