Recent content by kranj99

True - I'm not a fan of partnerships neither. In this particular case though, our client is a non-EU Private Equity firm and we have found that it is easier to get them in front of EU investors (non institutionals, and so mainly family offices) if they have an EU setup like the Lux SCSp...

Indeed on the 100M AUM, but as far as I know this is only if the AUM is Luxembourg based. While I'm not 100% sure, I believe foreign assets are not subjected to this Furthermore if it is a closed-end fund, I believe the limit is 500M (LU assets again) - but I admit I'm not fully certain of...

We have a client looking to set up a PE Fund in Luxembourg. We are recommending a sort of Special LP (SCSp) - main advantage is that it is not regulated, yet can qualify under AIFM directives and no approval needed from the state authority CSSF. Also ISIN and Bloomberg tickers can be allocated...

Was wondering if CFC rules do not apply within the EU? Because on one hand a part of EU law is that an EU citizen can open a company in any EU country. But if CFC rules were to apply, wouldn't this counter EU law?

My experience is that if you are non-US resident (i.e you don't have an SSN in your name) and you set up a US LLC in any state (with full compliance like EIN etc.), sometimes the payment processors reject you. I mean first they may approve you and then a few months later, Stripe, Paypal etc...

So I'm looking to incorporate an entity in an attractive jurisdiction that will actually have physical inventory of various goods. So I want to set up a company with at least perceived substance (i.e. inventory, warehousing, banking, merchant card processing, e-commerce presence etc.) with the...

Indeed well said. While the EU may not be perfect, the overall model works pretty well. Yes taxes can be on the high side, but so are the opportunities to make good money and live a good life. High tax countries in Western Europe have their fair share of billionaires living there, so it's not...

I sort of share this opinion. Most high tax western EU countries have so many 'write-off' opportunities that you can still benefit a lot simply staying put. It really only makes sense to shift your tax base if you are in a situation where you will gain substantially more revenue (i.e. larger...

If you speak French or German, you can find some local fiduciaires on anibis.ch - a sort of craigslist for Switzerland, but with some decent links to business service providers. Otherwise some that I've heard to have good reputations: Home - Fiduciaire LEVEL UP Genève , Ma-Societe.ch - Soutien...

I wanted to check this out more but when I went to the site, I got distracted

Monaco is not feasible without being of very high net worth. A few million won't cut it there. I mean for those of modest means, just the property rental prices alone would negate any tax benefit. Switzerland is not so attractive in the sense that what you get in return for your taxes in other...

Well these types of drops are nothing new. BTC is a volatile instrument. But volatility is just the price one needs to pay if one wants to be in this space. I first got in back in 2016 and been through many ups and downs. Right now, this does not feel like a bear market, based on past...

Just wondering how EU directives would work with regards to substance. Say the said poster becomes a German tax resident and then sets up their holding in another EU member state that has a slightly favourable holding regime, but not an all-out tax haven. For example The Netherlands, or...

SwissBorg is another one that works with Instant SEPA - I've tried it a few times and never had any issues.

Thanks for this - I am not too familiar with the specifics on the BC LLP but now you have given me something to explore a bit more!