Latin and South America

Following the Madoff scandal we advised the investment arm of a bank trustee with numerous Central and Latin American settlors / beneficiaries who had exposure to Madoff.

We provided thorough advice to an Argentinean hotel chain on tax optimizing its global structure for US investment and expansion. This included extensive pre-IPO planning, interim financing structuring, a review of the fund documents and the creation of convertible notes for a special class of investors.

We worked alongside Brazilian counsel to advise a client on the FATCA and CRS reporting requirements applicable to their complex succession structure for his offshore assets. These included a private trust company, trusts, companies and other entities, a private investment fund and multiple investment accounts, and involved the Bahamas, the Cayman Islands, Switzerland and the US. The advice also needed to take into account the client's plans to relocate his family from Brazil to London, and possibly thereafter to New York City.

A Chilean family's child was an accidental American by virtue of birth, and we helped them to address US tax reporting issues and eliminate future entanglement with the US.

A Chilean client engaged us to advise on their investment in the AIM-listed Brazilian gold producer Serabi Gold.

Working with a Chilean–US family, we helped to address compliance deficiencies in their family wealth succession planning structure. Small modifications to the structure substantially decreased US annual taxation and simplified reporting, addressing the US family members' income tax, FBAR and FATCA reporting issues. We also liaised with Chilean banks to quickly unfreeze needed accounts.

We helped the US-resident daughter of a successful Chilean entrepreneur through immigration issues and residency planning, supported tax and reporting efficient giving from her father, and provided cross border structuring advice.

We represented a Colombian family with interests in Colombia and Brazil, which had been briefly stationed in the United States, with a delicate IRS matter. We assisted the family in negotiating a penalty abatement of upwards of US$1.6 million in potential penalties, and all of the IRS meetings and negotiations were addressed without clients needing to be physically present in the United States.

Our litigation team acted in Ecuador v Colombia (Aerial Herbicide Spraying) Counsel of Colombia, in an ICJ case involving issues of international environmental law.

Our client was an Italian company which supplied customised speedboats for use by the Brazilian Police Force. We represented our client in the recovery of a debt owed by a Brazilian company involved in the transaction.

A telecommunications equipment manufacturer providing customer financing for the construction of telecom fiber networks in Mexico and other Latin American countries engaged us to advise.

A Brazilian private equity fund executive requested advice on pre-immigration planning in connection with his relocation to the United States. We helped to coordinate the timing of his tax recognition from certain transactions to occur while he was still a Brazilian tax resident and others to be taxed after becoming a US tax resident. We also established different types of trust structures to protect assets from US estate tax, a foreign trust to defer income taxation on existing carried interests, and a traditional US estate planning trust for carried interests not yet paying out.

We represented investors investing in a high-end Italian food market chain comprised of restaurants and food stations in New York, Chicago and Sao Paulo, Brazil.

A family office, based in Florida, USA, carrying out an underlying investment in the Venezuelan dairy sector sought our advice on the deal.

Aided a Brazilian family with significant US commercial real estate holdings to restructure the ownership of this property to avoid US estate tax. Also devised arrangements for Brazilian residents to create legitimate structures that are protected from Brazilian taxation, permit efficient repatriation of capital to Brazil when needed and ensure optimal flexibility and family control to respond to changing needs and tax laws in the future.

Represented a prominent Chilean businessman to secure and sustain his assets for his US-born descendants by allowing him to avoid US estate tax and reduce his Chilean property tax payments using usufruct transactions.

Advised clients with cross-border interests in relation to the construction of private trust company structures, which effectively allowed for family business succession planning, cost reduction and greater control over certain trust decisions and tax minimization in the jurisdiction of domicile and internationally.

Advised on the restructuring of a Colombian family's offshore assets in connection with Colombian tax reform.

Advised a Colombian family on the surrender of their US passports in order to come into compliance with their US tax and reporting obligations and thereby cease to be subject to US compliance in a highly tax efficient manner.

Assisted a major Brazilian real estate investor to immigrate to the US, start a new business, acquire US real estate and reorganize his Brazilian and offshore investments. This involved obtaining a new passport and visas, international tax and corporate structuring, real estate advice and business planning.

Advised on the creation of a long term governance and succession planning structure for one of the wealthiest families in Argentina in order to ensure family control of the business across generations, educate younger generation family members on governance responsibilities and protect the value of the holdings.

Represented a wealthy Argentine family to structure trusts for both their personal and business interests. Our planning allowed this family to minimize domestic wealth tax, ensure compliance with US tax regulations, form a voting trust for the family business and facilitate commercial lending transactions.

Creating US revocable and irrevocable trusts for the US children of Peruvian parents to enable the children to benefit from their parents' Peruvian wealth without causing US estate taxation and optimal income taxation.

Advised on the sale of assets in Venezuela and global residency, immigration and planning needs for a Venezuelan family needing to temporarily or permanently leave their country.

Acted for a Venezuelan family concerned about security and control of the family's assets now and for future generations. This resulted in a comprehensive restructuring of their worldwide assets, including the reorganization of existing trusts and creation of a flexible set of arrangements for the migration of trusts to separate jurisdictions for different beneficiaries.

Handle sale out of multiple apartment assets owned by an offshore fund, together with windup of entity. Windup and liquidation of foreign corporation included issues of law of Curacao, Hong Kong and California/US.

Advised on the development of multiple leveraged, tax-advantaged aircraft lease financings in North and South America for one of Israel’s largest aircraft companies.

We assisted US based and NYSE listed telecommunication companies in various assets acquisitions in Mexico, Brazil and Argentina.

We worked with a South American family with significant business interests when they chose to liquidate holdings in a multi-billion dollar business outside their home country. The family wanted to diversify their exposure and explore more sophisticated investment opportunities. We advised on the creation of a holding structure for their investments and helped them to establish a family office, based in New York, to advise it.