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Lux Fund A + Lux Fund B — Visual Structure Map
Interactive diagramsFund A: Blocker + debt flowsFund B: 5-investor cap tableNot a CFC (U.S. ≤ 50%)
Educational visualization only. This maps concepts (control thresholds, blocker layer, and loan flows) at a high level.
Structure 1 — Lux Fund A owns U.S. assets via a U.S. C-Corp Blocker
Toggle: Lux-level borrowing → optional intercompany loan down to blocker.
Fund A toggles
Use these to visualize debt at Lux and how proceeds can be moved down to the blocker.
Lux Fund A gets a loan
Debt at Lux fund level (senior facility / NAV line, etc.).
Intercompany loan to U.S. Blocker
Lux lends proceeds down to blocker (arm's-length in real life).
What this illustrates
• Blocker pays U.S. tax on U.S. operating income.
• Lux-level borrowing can create liquidity without a distribution (conceptually).
• Intercompany loan can move leverage "down" into the U.S. stack (conceptually).
Fund A diagram
You / Sponsor
Owns Lux Fund A interests
Equity
Lux Fund A
Has external debt facility
Owns 100% of blocker
U.S. C-Corp Blocker
Pays U.S. corporate tax
External Lender
Funds Lux facility
Loan proceeds
Lux Fund A (Debt)
Receives proceeds
Intercompany loan →
U.S. Blocker (Debt)
Borrower to Lux fund
Equity into U.S. assets
U.S. Real Estate / Ops
Income + appreciation
Note: In real implementations, related-party lending must be commercially supported (pricing, documentation, limits, deductibility rules).
Structure 2 — Lux Fund B holds liquid portfolio (stocks & bonds) with 4 other investors
Adjust cap table live. Goal: keep effective U.S. ownership ≤ 50% (simplified) to avoid "CFC current-tax" regime.
Cap table controls
Set ownership for you + 4 investors (target total = 100%).
Use this if one of the "other investors" is actually U.S. (simplified).
Total (should be 100%)100%
U.S. total (simplified)30%
If total ≠ 100%, the diagram still renders, but your cap table math is off.
Lux Fund B = liquid portfolio sleeveNot a CFC (U.S. ≤ 50%)
You (U.S.) — 30%
Keep ≤ ~30% (often used as buffer)
Equity
Lux Fund B (Portfolio)
Stocks • Bonds • ETFs • Reinvested P&L
Owns portfolio assets
Liquid Portfolio
Trading + income inside fund
Investor 1 — 20%
Non-U.S. (assumed)
Investor 2 — 20%
Non-U.S. (assumed)
Investor 3 — 15%
Non-U.S. (assumed)
Investor 4 — 15%
Non-U.S. (assumed)
What this is communicating (high level)
• If U.S. ownership/control crosses the line, you can end up in a "current inclusion" regime (conceptually).
• Keeping the portfolio sleeve in a vehicle not controlled by U.S. owners is often used to preserve deferral mechanics (depending on regime/elections).
This app is simplifying ownership tests and doesn't model attribution through trusts/entities.

Disclaimer

This interactive visualizer is provided for educational and illustrative purposes only. It represents simplified conceptual models and does not constitute tax, legal, or investment advice. Actual tax treatment, CFC rules, and international ownership structures are highly complex and fact-specific. Always consult with qualified tax and legal professionals before implementing any cross-border investment structure.

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