formerly Goltsblat BLP
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Bryan Cave Leighton Paisner (Russia) LLP — Russian Practice of Bryan Cave Leighton Paisner LLP, international law firm.
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Private Client

Advising heirs of a wealthy individual re inheritance case involving various assets in Russia and abroad. The complications of this case involved the need for distribution of the inherited assets among the heirs under the will and enforced heirs determined by the statutory provisions, as well as the assets including shares and participation interests in Russian entities. Fiduciary management was to be established over these. 

Advice provided to the ultimate beneficiaries of a leading independent investment management fund on tax effective ways to distribute a success fee from a Russian investment partnership to the ultimate beneficiaries of the Group through various entities located in the United Kingdom, the US, the BVI and the Cayman Islands.

Advising a private client on application of CRS to a trust established by a Russian tax resident individual. Advising on the Russian voluntary disclosure programme ("capital amnesty") and tax-free liquidation of foreign companies, providing turn-key support for the amnesty declaration and winding up of offshore structures, taking advantage of the transitional provisions of the Russian de-offshorisation law allowing controlled foreign companies (CFC) to be wound up tax-free in Russia, including the related reporting to be filed with the Russian tax authorities.
Jurisdictions involved: Russia, Switzerland.

Advising a high net worth individual, who was in the process of changing their tax residence from Russia to the UK, on the different aspects and risks of taxation of dividends to be received by this individual (with due account for his plans to distribute the dividends further to his foreign bank account). We based our analysis on the practical aspects of the tax legislation in Russia and the UK (we worked together with UK tax experts) and tried to find solutions that would allow the tax burden on the dividend income to be reduced, with due regard for the tax residence status of the individual in Russia and in the UK at any particular time. We also involved Cypriot tax experts in this project in order to discuss and assess jointly the tax consequences and risks in Cyprus associated with transfer of dividends from the Russian operating companies via a Cypriot holding company. Jurisdictions involved: Russia, UK.

Advising a Forbes top-100 Russian businessman and co-owner of a major Russian industrial group that has expanded into Europe on tax structuring of his participation in terms of the wider group restructuring, including advice on set-up and maintenance of his private holding company, as well as selected inheritance advice and other relevant tax issues related to on-going management of his investments. Jurisdictions involved: Russia, Cyprus, Gibraltar.

Advice provided to an high-net-worth individual on the personal income tax consequences of acquiring and subsequently selling shares in a Russian business.

Advising a well-known Russian game producer, mostly specialising in mobile and social games, on application of the Russian CFC rules to his offshore structures and the related tax compliance obligations.

Advice to a private client on the Russian currency control rules.

Tax advice concerning the choice of jurisdiction for a company to hold private assets (real estate and a yacht) and portfolio investments. We provided comprehensive advice involving multiple jurisdictions. Our advice covered not only tax issues (including gift tax, income tax and wealth tax) but also currency control and immigration law aspects. It was very important to identify how the laws of several jurisdictions apply in conjunction for particular situations/transactions.

Advising beneficiaries of a major player on the taxi aggregator market in Russia on applicability of the Russian beneficial owner rules and withholding tax rate on dividends paid by a Russian operating company. We also advised on the applicability of the Russian CFC rules to offshore companies controlled by the beneficiaries and prepared the full set of CFC reporting, including related CFC notifications and tax declarations with CFC profits, for submission to the Russian tax authorities.

Comprehensive legal and tax advisory support for the ultimate beneficiary of a major Russian equipment manufacturer. Our task was to revisit the entire Group’s corporate structure and wind up excessive offshore companies and trusts/foundations, taking advantage of the Russian de-offshorisation law incentives. We are also advising the beneficiary on developing an effective new holding structure. The project was complicated by the need to restructure/settle various intercompany debts and to coordinate restructuring steps in several jurisdictions.

Advice provided to the ultimate beneficiary of a major investment group on restructuring the current group structure, including winding up excessive offshore companies, taking advantage of transitional provisions of the Russian de-offshorisation law allowing controlled foreign companies (CFC) to be wound up tax-free in Russia. The project was complicated by the need to restructure/settle intercompany debt without violating the currency control restrictions. 

Advised the beneficial owner of a major consulting group on the tax aspects of a contemplated liquidation of the foreign holding company aimed at using the tax benefits granted by the tax amnesty and obtaining direct ownership of some Russian assets. As a result of the liquidation, the beneficial owner planned to gain some valuable assets, including rights of claim. There were several complications to the project (for instance, bankruptcy of one of the affiliated Russian companies) and we had to assess and propose to the client some alternative solutions that might better suit his needs without creating any significant tax risks for the beneficial owner and the Group. 

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Andrey Goltsblat
Managing Partner (Russia), Bryan Cave Leighton Paisner (Russia) LLP (formerly Goltsblat BLP in Russia), Senior Partner, Private Client, M&A, Investment Projects
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© 2009-2019 Bryan Cave Leighton Paisner (Russia) LLP is a limited liability partnership registered in England and Wales (registered number OC340589). Registered office: Adelaide House, London Bridge, London EC4R 9HA, United Kingdom. Winner - International Law Firm of the Year legal500 top ranked
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