Find out which conclusions your structure can support
You may have an existing arrangement, a new proposal or several advisers giving apparently incompatible answers. A defined review can establish which facts and rules support the position, which assumptions remain untested and what needs to change.
The review starts with a question. It could be the residence of a company, a proposed move, the role of a management provider or whether the combined arrangement makes sense. Defining the issue keeps the work useful and makes clear when a broader redesign is necessary.
Know what stands up, what is missing and what to do next
- A defined review of the relevant facts, documents and advice.
- Findings that separate supported conclusions, uncertainties and material inconsistencies.
- Prioritised next steps, with any redesign or implementation work made explicit.
When this is a good fit
This fits an existing arrangement, a proposal you have not implemented or conflicting advice you need to reconcile. Tell us about live deadlines at the outset.
Why work with Offshore Capitalist
We test the reasoning against the actual business and relevant sources. The aim is an answer you can examine and discuss, with evidence gaps identified instead of hidden behind a confident conclusion.
Compare the written plan with the operating facts
A structure diagram shows entities and ownership. It may not show who makes decisions, where work is done, how an important contract is performed or how money ultimately reaches an owner. Those facts can be decisive.
We review the relevant advice alongside the actual arrangements. A difference is not automatically a defect: the business may have evolved, a dependency may never have been implemented or the original analysis may have answered a narrower question. The first task is to identify the discrepancy accurately.
| Review layer | Questions to test |
|---|---|
| Facts | Are the owners, countries, activities and transactions complete and current? |
| Rules | Are the relevant domestic rules, treaty provisions and periods correctly identified? |
| Reasoning | Does the conclusion follow from the facts, or depend on an unstated assumption? |
| Implementation | Were the required appointments, contracts, registrations and operational changes completed? |
| Continuing position | Have subsequent events changed the basis for the original recommendation? |
Resolve disagreement by making the assumptions visible
Two advisers can reach different conclusions because they are analysing different facts, different taxes or different time periods. One may address corporate residence while another addresses the shareholder’s CFC exposure. A useful review separates the questions before comparing the answers.
Important statements should be connected to their supporting authority and conditions. If a conclusion depends on an exemption, identify its requirements. If a treaty is relevant, examine the provision and eligibility. If factual evidence is missing, the output should identify the gap rather than substitute confidence for proof.
A deliverable you can act on
The review should distinguish supported positions, unresolved questions and material inconsistencies. It should prioritise next steps, explain why each issue matters and identify the evidence or specialist input needed to resolve it.
That may support keeping an existing arrangement, making a limited change or commissioning a new design. The recommendation is not automatically to replace everything. Where implementation is appropriate, it is quoted and scoped as its own work rather than hidden inside an undefined review.
Agree the boundaries before the file arrives
We establish the entities, people, countries, periods and documents included. A current-year review is different from reconstructing historical filings, and a strategy assessment is different from handling a live tax-authority enquiry. Time-sensitive disputes or filing deadlines should be disclosed at the start.
Our work is consulting and advisory. Local formal opinions, amended returns, representation before an authority or other regulated work are included only where expressly agreed with the appropriate provider. The deliverable should state its scope clearly enough to be understood by another adviser.
The first useful information
Tell us what you are trying to establish, what has changed and whether there is an immediate deadline. A current structure chart and a short description of the competing conclusions are helpful. Detailed advice and confidential documents can then be shared through the agreed process.
A focused paid conversation with Michael may be sufficient for an initial issue. Where the question needs document review and research, the team will define a fixed deliverable and quote the work.
Scope, cost and the next step
The first inquiry is free. Tijana and the team establish the situation and propose the appropriate engagement. We confirm the deliverables, fee basis, external charges and timing dependencies before you commit. A focused paid call with Michael may be useful when a specific question needs his input.
Describe the countries involved and the outcome you want. We will identify the information needed to make the scope concrete, rather than quote a package that leaves essential work unspecified.
Document checklist
Track your preparation in this browser. Final requirements depend on the route and filing authority.