AQS Patrimonio Merchant Bankers

Family Office Tax Map — CFC vs PFIC vs Blocker + Liquidity Simulator

v0-readyNon-CFC Foreign CorpAudit-risk proxy: 0/100

Interactive diagrams + rules engine + compounding simulation. Educational modeling only — not tax/legal advice.

Interactive Structure Diagram

Toggle attribution, entity type, blocker, and asset mix and watch the classification update.

You (U.S. Person)

Direct: 30% • Effective: 30%

→

Lux Fund B (Portfolio Vehicle)

Entity: Foreign Corporation • Passive share: 20%

Other Owners

Other U.S.: 10% • Non-U.S.: 60% • Total (input): 100%

↓

Fund A (Operating Sleeve)

Op share: 80% • Blocker: Yes

U.S. C-Corp Blocker

Tax at blocker: 25.50% • Interest/163(j) on

→

U.S. Real Estate / Operating Assets

Base: $200.00M • Yield: 6.00% • Growth: 3.00%

U.S. total (effective): 40%Not a CFC (≤50% U.S. ownership)PFIC less likely (proxy)Non-grantor-like toggle (less attribution)

Not a CFC; portfolio may still be PFIC depending on actual income/asset tests.

Quick Toggles

The "big levers" that flip regimes.

Your direct ownership: 30%

Attribution (manual)

Adds attributed % to your ownership.

Trust is grantor-like

Forces attribution on (simplified).

U.S. blocker present

Contains U.S. operating income taxation.

Passive share in Fund B: 20%

PFIC proxy flips "likely" at ≥50% passive share.

What this app covers

Map: Ownership + attribution + blocker + asset mix → regime (CFC/PFIC/flow-through).
Rules: PFIC elections and a simplified CFC current-inclusion proxy.
Simulation: Compounding of operating and portfolio sleeves with modeled taxes and an optional PFIC "exit tax proxy."
Liquidity: Borrow vs distribute and how basis can turn distributions into taxable gains.

Important Disclaimer

This tool is provided for educational and illustrative purposes only. The models, calculations, and tax scenarios presented are simplified and do not constitute tax, legal, or financial advice. Tax laws are complex, jurisdiction-specific, and subject to change. Actual tax consequences depend on numerous factors not captured in this model.

Before making any investment, structuring, or tax-planning decisions, you must consult with qualified tax advisors, legal counsel, and financial professionals who can evaluate your specific circumstances. AQS Patrimonio Merchant Bankers and the creators of this tool assume no liability for decisions made based on the information provided herein.