KKMP Partner Alexander Anichkin spoke at the session “Tax Disputes and Business Strategies: Risks, Compliance and Efficiency” with a report titled “Peculiarities of Taxation when Using Personal Funds with Foreign Assets.” Specifically, during his presentation, Alexander highlighted:
sanctions and counter-sanctions aspects that must be considered when structuring ownership of foreign assets through personal funds
the problems of qualifying certain types of income that a personal fund may receive from foreign assets for the purposes of calculating the share of “passive income”
the procedure for notifying about CFCs (Controlled Foreign Companies) included in the assets of a personal fund
the impact of undistributed profits of CFCs on the calculation of the share of “passive income” in the total income of the personal fund
the impact of cross-border transactions with digital currencies on the possibility of a personal fund using a reduced corporate income tax rate.