AQS Patrimonio Merchant Bankers

Lux Master Dashboard

Structures + valuation uplift + liquidity + posture labeling (visual + interactive).

Not a CFC (U.S. ≤ 50%)IRS posture: SAFE

Posture layer: This is a proxy score to help you communicate "how conservative the structure is" (CFC exposure, blocker presence, related-party debt complexity, and cap table hygiene).

Lux Fund A — Blocker + Debt Flow

Toggle Lux facility + intercompany loan and see animated flows.

Fund A toggles

Lux Fund A gets a loan

Debt at Lux fund level.

Intercompany loan to U.S. Blocker

Lux lends proceeds down to blocker.

U.S. blocker present

Contains U.S. operating income taxation.

Narrative

• Borrowing is shown as "flowing" without a distribution.

• Intercompany debt adds complexity (pricing/docs/limits).

Fund A diagram

You / Sponsor

Owns Lux Fund A interests

Equity

Lux Fund A

Has external debt facility

Owns blocker

U.S. C-Corp Blocker

Pays U.S. corporate tax

External Lender

Provides debt

Loan proceeds

Lux Fund A

Receives loan

Intercompany loan

U.S. Blocker

Receives interco loan

Lux Fund B — Cap Table + CFC Stress Test

Adjust ownership to model U.S. control. If "You + Other U.S." > 50%, you see the CFC risk pill.

Fund B ownership

You (U.S.): 30%

Investor 1: 20%

Investor 2: 20%

Investor 3: 15%

Investor 4: 15%

Other U.S. persons (CFC stress test): 0%

Summary

Total (You + Investors): 100.0%

Total U.S. ownership (You + Other U.S.): 30.0%

Narrative

• If U.S. persons > 50%, the fund is likely a CFC.

• Add more non-U.S. investors to reduce control.

• This is a simplified proxy; real rules are nuanced.

LEGAL DISCLAIMER

This dashboard is provided for educational and illustrative purposes only and does not constitute tax, legal, accounting, or investment advice. The calculations and visualizations are simplified models and may not reflect the complexities of actual tax law, including but not limited to IRC Subpart F (CFC rules), PFIC regulations, transfer pricing, and other relevant provisions. Tax treatment varies significantly based on specific facts and circumstances, jurisdictional rules, and evolving regulatory guidance. Before implementing any structure or making any decisions, you must consult with qualified U.S. and Luxembourg tax advisors, legal counsel, and other appropriate professionals. No warranty is made as to the accuracy or completeness of this information.