Design and repair of international structures: companies, holdings, trusts, foundations. Lawful, substantive, fully reported — with defence ready if the structure is already under scrutiny.
The legal services described on this page are provided through Cabinet de avocat Mihai Guran (Brașov Bar). This page is informative.
About the attorney →A foreign company, a trust, a foundation or an international holding are lawful instruments — provided they are built with real substance, reported correctly (UBO, CRS/FATCA, DAC6) and serve genuine purposes: asset protection, succession planning, cross-border investment, legitimate privacy.
The line between a resilient structure and a liability is not the jurisdiction — it is substance and transparency: who actually controls the assets, where decisions are made, what is disclosed, and whether the arrangement has economic rationale beyond the tax advantage.
As a Romanian tax lawyer who is also a certified tax adviser and a court-appointed forensic tax expert, I design and repair international structures with both sides in view: lawful optimisation, and the exact point where reclassification, penalties or a criminal file begin.
Choosing the right jurisdiction and vehicle — company, holding, trust, foundation — for the actual goal: protection, succession, investment or exit. With real substance, not letterboxes.
Beneficial-ownership registers, automatic exchange of information (CRS/FATCA), reportable cross-border arrangements (DAC6/MDR), CFC rules — the structure that sleeps well at night is the one properly disclosed.
Stress-testing inherited or legacy structures: do they still hold today? What risk has accumulated? A regularisation or restructuring plan — before the tax authority asks the questions.
When the structure is already challenged — tax reclassification, tax-evasion or money-laundering allegations — the technical and the legal defence come from the same hand: the one that understands how it was built.
Yes — ownership of foreign entities is lawful when beneficial ownership, income and accounts are properly reported and the structure has real substance. What is illegal is concealment, not the structure itself.
Yes. Over one hundred jurisdictions exchange financial-account information automatically. The correct strategy is lawful structuring and accurate reporting — legitimate privacy is achieved through legal instruments, not silence.
Many pre-transparency structures (built before CRS, UBO registers, DAC6, CFC rules) were never adapted. An audit establishes what still holds, what needs regularisation, and how to transition without manufacturing evidence against yourself.
The deadlines for challenging run from the date of communication. An early assessment establishes whether and on what basis a challenge can be built, and what must be protected immediately.