"Tax Compliant Investment Holding Structures for Latin Americans focusing on Mexico, Brazil and Venezuela.

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1 "Tax Compliant Investment Holding Structures for Latin Americans focusing on Mexico, Brazil and Venezuela. Hywel Jones & Gerald Dickens STEP Bahamas Luncheon Tuesday, February 28, 2006

2 Contents Overview of market and fundamental issues Mexico Brazil Venezuela Summary and conclusion

3 Overview Nature of Structures 1) INITIAL INVESTMENT 2) HOLDING PERIOD 3) EXIT STRATEGY NEW OR ALREADY OFFSHORE? WHAT STRUCTURE? LIFETIME OR DEATH OFFSHORE OR ONSHORE

4 Overview New Money Offshore Compliant Offshore Offside Mexico Brazil Venezuela

5 Overview Fundamental issues Tax Reporting Currency controls Solicitation Political/Economic Pasquantino

6 Mexico 2005 Tax changes Blacklisting replaced with Preferential Tax Regimes Scottish trusts, Singaporean corporations, Netherlands Antilles partnerships etc. noncompliant Disillusioned Clients why bother to change again?

7 Mexico Why bother to change? Upcoming Election and AMLO Criminal Prosecutions Flight Money of 30/40 years ago wants to go back Demographic Shift and Aging Parents Compliance Issues for Bank/Trustee Pasquantino

8 Mexico - Solutions Declare Funds! Split Trust Single Premium Life Insurance Composite Insurance

9 Settlor & Beneficiaries Beneficiaries: family but not Settlor Revocable Trust Irrevocable Trust A. Capital Stock B. Income Stock Singapore Portfolio Securities Miami/296755

10 Mexico Single Premium Life CLIENT ASSETS MEXICAN BENEFICIARIES PREMIUM LIFE POLICY INVESTMENTS DEATH

11 Mexicans Offshore life Mexicans can purchase life and disability insurance outside Mexico Sale of policy must occur outside Mexico i.e. solicitation, completion of application, issue & delivery of policy, etc. Insurance must be valid in country of issue Same tax treatment as Mexican-issued policies Reinsurance outside Mexico not subject to Mexican law

12 Purchase of Policy Sale of policy must occur outside Mexico Premium can be paid from Mexico single or multiple premiums Payments to Preferential tax regimes must be reported to Hacienda Premium must be paid by insured NOT an entity i.e. by living person or possibly by an employer as employee benefit

13 Assets held under policy Tax free income/growth from policy investments BUT BEWARE: Currently no risk/investment ratio requirement but guidelines are anticipated Policies with investment element should comply with internationally accepted minimum ratios i.e. there should be substantial insurance risk Investor control issues important - client cannot manage investments or reinsurance terms Absent the above there is the danger of recharacterization as an investment triggering taxation

14 Policy Proceeds Tax free on death Tax free on disability lump sum or pension Tax free if maturing in life time of insured provided: - minimum 60 years old - insurance contract in place for 5 years Can be lump sum or annuitised benefit

15 Mexico Composite Insurance EXISTING CLIENT LIVE MEXICAN ANNUAL PREMIUM REINSURANCE STRUCTURE INVESTMENTS REINSURANCE TREATY OFFSHORE LIFE POLICY DEATH BENEFIT

16 Mexico Disability Pension Exit EXISTING CLIENT MEXICAN NATIONAL ANNUAL PREMIUM REINSURANCE STRUCTURE INVESTMENTS REINSURANCE TREATY DISABILITY POLICY TAX FREE PENSION

17 Summary Sale must take place outside Mexico Payment of premium must be reported No client control over investments or reinsurance Correctly structured - no taxation On issue On policy investments On distribution

18 Brazil Residents taxable on worldwide income Direct investment abroad in financial investments taxable to individual whether received or not But no anti-deferral rules Can capitalise IBC no tax until income received in Brazil

19 Brazil Direct Investment EXISTING CLIENT EXISTING CLIENT OFFSHORE CORPORATION FINANCIAL INVESTMENT FINANCIAL INVESTMENT

20 Brazil Donations/Trusts BRAZILIAN RESIDENT DONATION OFFSHORE TRUST

21 Brazil BRAZILIAN RESIDENT BRAZILIAN BENEFICIARIES DONATION OFFSHORE TRUST LIFE POLICY

22 Overview Brazilians can purchase life insurance outside Brazil Must be contracted outside Brazil Must be valid in country of issue Same tax treatment as Brazilian issued policies No solicitation in Brazil allowed Reinsurance arrangements for insurer outside Brazil not subject to Brazilian law

23 Brazil OFFSHORE ASSETS REISNURANCE STRUCTURE LOANS DOMESTIC ASSETS BRAZILIAN RESIDENT OFFSHORE LOAN PREMIUM LIFE POLICY BENEFICIARIES

24 Purchase of Policy 1 Funds in Brazil Central Bank approval Sale of policy must occur outside Brazil i.e. solicitation, completion of application, issue & delivery of policy, etc Rules attempt to prevent placement of insurance outside Brazil other than risks not covered domestically Central bank approval required for payment of premium from Brazil to foreign insurer Transfers to foreign bank accounts in clients name OK but only on temporary basis not for insurance

25 Purchase of Policy 2 Funds in Brazil Central Bank exemptions Three exemptions from Central Bank approval 1. Authorised by Brazilian reinsurance monopoly (IRB) 2. Involves risks outside Brazil 3. Beneficiary is outside Brazil Even if one of the above exemptions exists, Central Bank still has discretion to authorise/decline

26 Purchase of Policy 3 Funds outside Brazil reporting rules Declared funds already abroad can be used to pay premiums Loans taken abroad can be used to pay premiums e.g. premium finance by insurer Both loan and policy must be reported on tax return but no resultant taxation No requirement as to interest rate or term of loan zero interest permitted Interest payments paid from Brazil subject to withholding tax.

27 Treatment of policy assets in lifetime Taxation and loans No taxation or reporting on income/growth of policy assets Return of premium in lifetime not subject to tax - other withdrawals taxed as income No tax or restrictions on interest or term of policy loans outside Brazil but must reported Withholding tax on interest paid from Brazil Brazilian assets can collateralize foreign loans No investor control issues if OK in country of policy issuer

28 Termination of Policy Taxation of proceeds No income, estate/inheritance, or wealth tax to beneficiaries on death must be lump sum payment Cancellation in lifetime proceeds subject to income tax apart from returned premium Reinsurance arrangements for insurer not subject to Brazilian law, taxation or reporting Owner/beneficiary can be legal entity Can insure 3 rd parties provided insurable interest

29 Summary Sale must take place outside Brazil Payment of premium preferably paid with funds outside Brazil declared funds or loan Policies and premium loans declared on tax return but no tax Policy loans also not taxable Flexible rules on interest/term of loans No taxation on purchase, growth in policy assets or on death Reinsurance not subject to Brazilian law

30 Venezuela Bad laws aggressive enforcement Blacklisting - Flight capital mode Transactions with non-treaty jurisdictions assumed non-arms length Possible introduction of wealth tax Cash in non-interest bearing accounts in high tax jurisdictions no tax/reporting Trusts settled with compliant cash no tax/reporting Trust proceeds - profits taxable

31 Venezuela NON INTEREST BEARING ACCOUNT TRUST LIFE POLICY DEATH BENEFIT

32 Venezuela issues Can fund structure from checking account Gift tax is territorial No tax or reporting for trust but profits taxable on distribution Trust should avoid potential wealth tax Insurance provides additional clarity on no tax and exit strategy Barbados

33 Venezuela life insurance issues Article 4(1) of insurance law foreign policies unenforceable Policy purchased outside by non-venezuelan i.e. trust OK Proceeds of policy must go to trust to preserve character also possible gift argument May be asked to demonstrate no investor control Segregated account policies care re classification as investment

34 Venezuela New Money/Treaties Currency Controls Countries with no treaty and less than 20% income tax assumed non-arms length Double Investment Treaties Barbados Use UK, New Zealand etc. Captive Insurance

35 Venezuela US LLC SPAIN ETVE VENEZUELAN COMPANY

36 Venezuela VENEZUELA COMPANY P& C PREMIUM RATED INSURANCE COMPANY REINSURANCE STRUCTURE INVESTMENT BARBADOS INSURANCE CO. TRUST LIFE POLICY BENEFICIARIES

37 Venezuela - Summary Money outside Venezuela trusts OK Life insurance adds more protection and exit strategy New money out of Venezuela opportunities with treaty countries dividends Captive insurance

38 In summary Latin America moving towards Mexican style rules Brazil, Venezuela existing structures can still be compliant New money currency controls better working with offshore money while compliant If existing structures allowed to lapse problems Pasquantino!

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