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Service 07

Structuring & foundations

Entity and group design that survives contact with a regulator, a tax authority and an exchange listing.

Why this is hard

A legal wrapper solves liability and legal personality. It does not solve tax: home-jurisdiction rules, controlled-foreign-company regimes, place-of-effective-management and economic substance tests all still apply, and a structure chosen for the wrapper alone tends to fail the substance test two years later when it is expensive to fix.

What we do

Inside this service.

Group structure design

Foundation, devco and issuer, modelled for tax, substance and regulatory outcome together.

Wrapper selection

Cayman, BVI, Swiss, Liechtenstein, Marshall Islands or Wyoming — chosen on consequences, not fashion.

Substance planning

What has to be real, where, and the annual file that evidences it.

Fundraising instruments

SAFE and token warrant, SAFT and the economics that follow from each.

Foundation governance

Council, supervisor and grant administration designed to be operable rather than decorative.

Redomiciliation

Moving an existing structure without triggering the events that make it costly.

Tell us what you are holding, and where.

We will tell you what applies to you, what is already late, and what it takes to fix. In Dubai, Dublin, London or Tokyo, in person if you prefer.

Speak to usFor accounting firms