01 / 09
International Tax Planning
Treaty-driven structuring designed to reduce the tax cost of international business, investment, and wealth management as allowed by law. We focus on the USA-Barbados and Canada-Barbados double tax treaties, including the path that takes a 30% US withholding tax down to 5% for a properly resident Barbados company. Where US tax planners default to 'check the box' and paying full US taxes, non-US owner-managers have meaningfully more options; we work with US tax counsel who treat international clients internationally, not as US domestic clients.
What's included
- USA-Barbados and Canada-Barbados treaty access
- Holding and operating company structuring
- US withholding tax reduction
- CFC and PFIC analysis for non-US owners
Schedule consultation02 / 09
International Private Investment Funds
For a non-US owner-manager to raise capital from US investors, the structure that owns the underlying business needs to be regulated. US investors and their advisors treat unregulated international structures as high-risk and will not transact through them. We typically set up a Limited Partnership owning the operating company, with a General Partner regulated through a regulated director, a regulated asset manager as a shareholder, or a co-fund-manager arrangement.
What's included
- Limited Partnership / regulated General Partner formation
- Fund manager governance and director services
- Investor onboarding, subscription, and KYC
- Coordination with US counsel on offering materials
Schedule consultation03 / 09
Trust & Corporate Services
Director and trustee services for international structures we set up and operate ourselves. We only run structures we know and understand. Trust work focuses on three areas: fiduciary duty (frequently missing from civil-law agreements imported from Latin America), asset-protection trusts (US domestic for clients becoming US persons; US foreign trusts for those who are not), and long-term estate planning ahead of the US 40%+ estate tax. Corporate services keep companies properly resident in Barbados, Canada, or the USA, which is what unlocks the relevant tax treaty.
What's included
- Independent directors and professional trustees
- US domestic and US foreign asset-protection trusts
- Canadian trusts tax-resident in Barbados
- Corporate secretarial, registered office, compliance calendar
Schedule consultation04 / 09
Compliance Services
Ongoing compliance across the jurisdictions in which a client's structures sit. Beyond the regulatory filings, our internal CRM tracks every compliance date across the corporate stack (Barbados companies, US LLCs and C-Corps, Canadian companies) so nothing slips. Bank access depends on compliance; failures here become bank-access problems before they become regulatory problems.
What's included
- Common Reporting Standard (CRS) and FATCA filings
- Economic Substance reporting
- AML and continuous risk assessment
- Beneficial ownership reporting and annual renewals
Schedule consultation05 / 09
Captive Insurance
Captive insurance structuring built on Barbados's position as one of the world's largest captive jurisdictions, with over 310 captive companies on the island. For owner-managers raising US capital in oil & gas or mining, a captive that reinsures the operational risk of the business gives US investors a tangible mitigation strategy to reference in the offering memorandum, and lets the owner negotiate control terms with investors. For agricultural exporters, captives reduce the cost of letters of credit and performance bonds.
What's included
- Single-parent and group captives
- Reinsurance of Latin American and African operating businesses
- Risk-mitigation language for offering memoranda
- Licensing, regulatory liaison, and ongoing management
Schedule consultation06 / 09
Immigration & Relocation
Support for owner-managers and families relocating to or establishing presence in Barbados, Florida, or Canada. With automatic information exchange now operating across most major jurisdictions, where the family lives matters as much as how the structures are set up. Residency needs to line up with where the international business and wealth platform is actually run from.
What's included
- Barbadian citizenship and permanent residence permits
- Welcome Stamp and special entry permits
- Full, temporary, and spousal / partner visas
- School and lifestyle introductions via Mithril Concierge
Schedule consultation07 / 09
International Fundraising
Helping non-US owner-managers raise capital legitimately in the United States, with deep experience in oil & gas, mining, and agricultural export. Latin American and African projects are viewed as high-risk by US investors and their advisors; US private-equity playbooks written for US domestic businesses do not apply. The reliable pattern is an International Private Investment Fund paired with a Captive Insurance company, which gives US investors both a regulated vehicle and a substantive risk-mitigation story.
What's included
- International Private Investment Fund formation
- Coordinated captive insurance for risk mitigation
- Instructions to US counsel on offering materials
- Reg D / Reg S analysis and investor onboarding
Schedule consultation08 / 09
Active Business Solutions
Operating support for international businesses. We help owner-managers run companies that are genuinely resident where they claim to be (directors, staff, offices, commercial reality), because that is what unlocks the relevant tax treaty and exempts the company from the Controlled Foreign Corporation rules that every Latin American nation operates. For agricultural and manufacturing exporters the Port-of-Miami corridor pattern works well: a Barbados parent with US operating presence, exports through Miami, operating profits outside US corporate tax. Since 2017 a US exporting subsidiary can achieve a 13% federal rate, and dividends received from subsidiaries are not subject to US corporate tax.
What's included
- Directors, office space, staff, management oversight
- Tax-residency setup in Barbados, Canada, or the USA
- Port of Miami corridor for exporters
- Financial accounting (IFRS / local GAAP) and audit facilitation
Schedule consultation09 / 09
International M&A
Many owner-managers in the US and Canada want to exit the business they built, tax-efficiently and on their own terms. The bulge-bracket banks and the Big Four are built around large-cap mandates; their engagement economics rarely fit a privately held SME, and owner-managers end up under-advised at exactly the moment that matters most.
We work the sell-side as a boutique. A treaty-resident Barbados company can serve as a tax-neutral platform for the cross-border merger or acquisition, leaning on the USA-Barbados and Canada-Barbados double tax treaties rather than on opacity.
For owners with a legacy or succession objective, charitable share structuring through a Barbados charitable trust can form part of the exit where the facts support it.
And where the deal sits squarely in one corridor, we coordinate US, Canadian, and UK M&A execution with tax counsel who treat international clients internationally.
What's included
- Barbados treaty-resident acquisition / merger platform
- Sell-side tax structuring across the US, Canada, and UK
- Charitable share donation into a Barbados charitable trust
- Coordination with US, Canadian, and UK M&A and tax counsel
Schedule consultation