Roksana specializes in providing comprehensive legal support to private clients under the family office model, helping them develop long-term strategies for wealth management, preservation, and succession planning.
Her experience covers the development of succession concepts, structuring of asset ownership (including through foreign trusts, companies, and Russian private foundations), migration of assets into Russian and international structures, as well as international tax planning and compliance related to the reporting of foreign assets, accounts, and income.
Selected Experience
Tax Advisory
Roksana advised:
private investors on the establishment and registration of an international IT company in the online gaming sector in Cyprus, including advice on the potential application of preferential tax regimes;
a major venture capital fund based in Cyprus and the United States on the applicability of controlled foreign company (CFC) rules to a foreign venture fund and private investors holding rights and interests in the foreign investment fund;
shareholders of a group of companies operating in the mining industry on the practical implementation of tax treaty benefits (application of reduced tax rates) under the Double Tax Treaty with Israel and the refund of excessive personal income tax withheld;
the founder of a major restaurant chain on the application of CFC legislation to the business ownership structure, including the development of step-by-step instructions for reporting interests in foreign companies, optimizing the ownership structure, and assessing the feasibility of applying the fixed profit tax regime for CFCs;
a private investor on selecting a foreign jurisdiction for establishing an investment holding company, taking into account the client’s investment strategy. Various jurisdictions were considered, including Cyprus, Singapore, Hong Kong, and Caribbean jurisdictions, to ensure maximum flexibility in trading public and private assets while maintaining an optimal tax burden.
Asset Ownership Structuring in Russia and Abroad
Roksana advised:
private capital owners on the liquidation of a US trust followed by the repatriation of assets to Russia after a succession event;
private investors on building international asset ownership structures, including the use of trusts, PPLI, corporate structures, and ACM, taking into account tax efficiency and asset protection objectives;
a private client on the phased liquidation of a trust structure in the Bahamas and the transfer of assets to family members, coordinated with a Swiss trustee and taking into account the beneficiaries’ tax residency and the characteristics of the transferred assets.
Succession Planning and Private Foundations
Roksana advised:
high-net-worth private clients on the development and implementation of comprehensive succession planning solutions, including preparation of trust documentation and transfer of assets into foreign trusts and foundations, taking into account tax implications;
private clients on the establishment and administration of private foundations in the Russian Federation for succession planning, asset protection, and enhanced ownership confidentiality, including the development of governance structures, determination of powers of governing bodies, and rights of beneficiaries.
Tax Reporting and Interaction with Tax Authorities
Roksana advised:
clients on more than 100 procedures involving tax-free liquidation of foreign companies and structures, including the application of capital amnesty mechanisms;
individuals during field tax audits, successfully challenging decisions imposing tax liability;
private clients in interactions with tax authorities during pre-audit reviews, preventing the initiation of field tax audits.
achievements
Ratings and Awards
Roksana is recognized by leading Russian legal rankings, including Pravo-300 and Rossiyskaya Gazeta in Private Capital and Investments nominations.