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Kristina Markova
Senior Associate
Kristina is an expert in tax planning, asset ownership structuring, and succession planning for high-net-worth and ultra-high-net-worth individuals and families (HNWI/UHNWI), with more than 7 years of experience in private client taxation.
She provides comprehensive family office-style support to clients, advising on the reporting of foreign assets, accounts, and income. Kristina has extensive experience in implementing projects involving the development of succession concepts, as well as the establishment and administration of Russian private foundations, trusts, foreign foundations, and companies.
She provides comprehensive family office-style support to clients, advising on the reporting of foreign assets, accounts, and income. Kristina has extensive experience in implementing projects involving the development of succession concepts, as well as the establishment and administration of Russian private foundations, trusts, foreign foundations, and companies.
Selected Experience
Tax Advisory
Kristina advised:
Kristina advised:
clients on selecting jurisdictions for relocation in order to enhance tax efficiency with respect to Russian and foreign asset structures (including Spain, Portugal, Italy, Switzerland, France, Malta, Andorra, Kazakhstan, the UAE, Saudi Arabia, and other jurisdictions);
the beneficiary of a major investment fund on Russian tax implications arising from the acquisition of a group of companies within a foreign structure (transaction value — USD 700 million);
a top executive of a Russian bank on Russian tax implications and currency control restrictions in connection with the restructuring of debt obligations arising from a series of transactions involving persons from “unfriendly” jurisdictions;
Asset Structuring
Kristina advised:
Kristina advised:
clients on the establishment and administration of Russian private foundations for succession planning and asset protection purposes, including enhancing confidentiality of ownership. Her work on these projects included developing foundation structures with respect to beneficiaries’ rights and governing bodies’ powers, as well as designing checks and balances mechanisms when appointing an external foundation manager;
UHNWI clients on the establishment and administration of a foundation in the UAE for asset protection and succession purposes in relation to assets located in the UAE, Cyprus, and Palau, including assisting with the transfer of assets into the foundation structure;
clients on the administration of trusts (Isle of Man, Cayman Islands, Cyprus), including trust redomiciliation projects and advising on tax implications of trust income generation and distributions to beneficiaries;
Individual Tax Reporting
Kristina assists clients with the preparation of:
Kristina assists clients with the preparation of:
personal income tax returns (Form 3-NDFL) in relation to income derived from foreign assets, including securities, futures, options, currency swaps, precious metals, and CFC assets under capital amnesty programs, as well as income received under employee incentive programs. She also prepares tax filings for the purposes of offsetting and carrying forward securities losses and applications for tax deductions. Kristina represents clients during tax audits and appeals against tax authority decisions;
CFC reporting and related compliance, enhancing clients’ tax efficiency through the application of CFC profit exemptions, adjustments to CFC reporting, and analysis of the feasibility of switching to the fixed-profit taxation regime for CFCs;
Russian foreign exchange control reporting, including representing clients in audits concerning compliance with Russian currency legislation.
achievements
Ratings and Awards
Kristina is recognized in the Pravo-300 individual ranking in the Private Capital category, and is also recognized by Rossiyskaya Gazeta.
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