We integrate corporate and tax advisory with hands-on execution: governance policies, supporting documentation, and regulatory filings, coordinating corporate bylaws and intercompany agreements directly with qualified legal counsel. We coordinate with local counsel and tax advisers in each jurisdiction and leave you with repeatable processes (templates, RACI matrices, and controls) so the group can maintain consistency month after month—even as teams and markets change.
Holding company and ownership chain design
Mapping of U.S. and foreign entities, purpose of each vehicle, and profit flows, with a forward-looking view toward expansion, M&A, and potential exits.
Tax residence and permanent establishment
Assessment of tax residency and permanent establishment tax risk based on effective management, personnel, contracts, and logistics; design of contractual and operational mitigations to avoid unintended tax presence.
Corporate governance and substance
Board structure, officer roles, board packs, and policies to demonstrate economic substance where required, coordinating legal documents such as powers of attorney with legal counsel to align with expectations from banks, tax authorities, and regulators.
Intercompany agreement structuring
Service, licensing, distribution, and cost-sharing agreements that reflect the actual business model and are consistent with the group’s transfer pricing policy.
Intra-group capitalization and financing
Capital structure, thin-capitalization considerations, loans, and guarantees; market-based support for terms and traceable cash flows across the group.
Compliance calendar and reporting
Jurisdiction-by-jurisdiction calendar covering corporate secretarial, accounting, and tax obligations (financial statements, tax returns, VAT/GST), and reporting obligations (for example, applicable FinCEN BOI requirements for foreign entities, FATCA, BEPS-related rules, and transparency regimes).
Documentation for banks and investors
A structured data room with group chart, KYC documentation, certificates of good standing, corporate minutes, and key policies to streamline onboarding, refinancings, and capital raises.
Alignment with transfer pricing
Margins and documentation consistent with OECD/IRS standards (Master File, Local File, and where relevant, CbCR) to reduce the risk of transfer pricing adjustments and double taxation.
We start with a diagnostic of your corporate footprint: legal entities, value flows, related-party arrangements, tax residency and permanent establishment risks, and reporting obligations (for example, FinCEN BOI reporting / corporate transparency act compliance, FATCA, BEPS-related rules, and transparency regimes).
On that foundation, we design an ownership architecture aligned with the business—holding company, operating subsidiaries, branches, or joint ventures—together with governance rules, intercompany agreements developed along with your legal advisors or ours, and a country-by-country compliance calendar.
Frequently Asked Questions
What is the practical difference between a holding company and an operating subsidiary?
The holding company concentrates ownership and high-level decision-making; the operating subsidiary runs the local business and assumes operational risk. Separating them helps organize risk, cash flows, and tax and regulatory compliance.
Do I need to report Beneficial Ownership (BOI) in the U.S.?
Under FinCEN’s current rules, entities created in the U.S. are exempt from federal BOI reporting. The requirement now focuses on certain foreign-formed entities registered to do business in the United States. We assess whether your foreign entity qualifies as a reporting company, verify applicable exemptions, and manage the required filings.
How do you manage the U.S. tax exposure of a commercial office?
By designing operations and contracts carefully: defining the scope of activities, authority to bind foreign entities, billing flows, and documentation that accurately reflects how the business is conducted in practice.
How long does it take to redesign structure and compliance?
A quick assessment typically takes 2–4 weeks. Phased implementation is often completed in 8–12 weeks, depending on the number of jurisdictions, required corporate changes, and new registrations.
Do you work with local advisers?
Yes. We coordinate with local counsel and tax advisers to align U.S. federal and state requirements with the rules in each foreign jurisdiction, avoiding conflicting instructions and closing compliance gaps.
What changed from GILTI to NCTI beginning in 2026?
For taxable years beginning after December 31, 2025, Section 951A transitioned from GILTI to Net CFC Tested Income (NCTI). We model the current Section 951A rules alongside applicable foreign tax credit and high-tax provisions, ensuring your international structure remains fully aligned under the updated framework.
Clear structure, sustainable compliance, and an operation ready to grow
We bring order to your ownership chain, reduce tax friction, and leave you with a repeatable, scalable compliance process. Schedule a 30-minute assessment and receive a structuring and compliance plan with milestones, estimated costs, and required documentation.
GUILLEN PUJOL CPA, P.A.
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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GUILLEN PUJOL CPA, P.A.
6161 Waterford District Dr., Suite 475 Miami, FL 33126
GUILLEN PUJOL CPA, P.A.
6161 Waterford District Dr., Suite 475 Miami, FL 33126
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