Consistent with optimizing investor returns, NDC Capital Partners assists clients in structuring transactions to address the principal U.S. federal income tax laws.  With respect to numerous transactions overseen by Anthony T. Niosi involving certain non-US residents, such investors have utilized variations of an offshore tax structure allowing for a reduction of the current federal income tax rate.

Non-US resident clients who have benefited from this tax structure in these platforms originate from countries around the world including:

The exhibit below illustrates the typical structure non-US residents have utilized. The structure requires the non-US resident to fund a US-based corporation (a Delaware Holding Company) through two newly created offshore entities in a jurisdiction that does not have an existing tax treaty with the U.S. In the example below, a Cayman Holding Company and a Cayman Finance Company are used. The federal income tax reduction is effectuated, in part, by the Delaware Holding Company issuing debt to the Cayman Finance Company.

The potential economic benefit of the above structure may result in higher after-tax profits. In a hypothetical transaction which garners a 20% IRR to the investor, a non-US resident investor would have an after-tax IRR of roughly 260 basis points higher using this tax structure.

THE FOREGOING TAX STRUCTURING AND EXAMPLE SUMMARY DOES NOT DISCUSS THE POTENTIAL STATE, LOCAL, AND FOREIGN TAX CONSEQUENCES OF AN INVESTMENT BECAUSE SUCH CONSEQUENCES ARE CONTINGENT ON WHERE THE PROPERTY IS LOCATED, WHERE THE INVESTOR RESIDES AND ON OTHER FACTORS. PROSPECTIVE INVESTORS ARE ENCOURAGED TO CONSULT THEIR OWN TAX ADVISORS REGARDING THE POSSIBLE IMPACT OF STATE, LOCAL AND FOREIGN TAXES (INCLUDING, BUT NOT NECESSARILY LIMITED TO, INCOME TAXES, TRANSFER TAXES, AND ESTATE OR INHERITANCE TAXES) ON THE PURCHASE OF COMMON STOCK IN CAYMAN FINANCE COMPANY AND CAYMAN HOLDING COMPANY.