The fourth stage of “capital amnesty” turned out to be unprecedented both in terms of the range of assets that may be declared and the surrounding political situation in the world. This stage opens the door for legalizing in Russia of ownership of financial assets, foreign companies (controlled foreign companies - CFCs), real property, vehicles, bank accounts and even cash.
Most of such assets (except, of course, foreign real property and CFCs) will have to be transferred to the Russian jurisdiction. In such case the declarant and a number of other persons are released from criminal liability for tax crimes, failure to credit foreign currency earnings, to pay custom duties and from administrative liability for violations foreign currency control regulations. The declarant will also be exempt of taxes which he should have paid in connection with the acquisition of those assets or receipt of income out of which the purchase price of such assets were paid. Furthermore, the beneficial owner of the assets may register them in his own name without having to pay tax on the income accrued as a result of transfer to him of the ownership of respective property. One should not leave unmentioned the unique opportunity to become an immediate owner of the assert owned by him through his CFCs. It is note worthy that exemption from taxes is possible even without liquidation of the company.
The main problem standing in the way of those who would like to avail of the broadest opportunities afforded by the “capital amnesty” is the countering sanctions imposed by unfriendly jurisdictions in which assets are located. Many Russian beneficiaries have already encountered difficulties in disposing of their property. For this reason, before joining the declaration campaign one should discuss with professional advisers the assets declaring procedure as well as organizational aspects of repatriation thereof from foreign countries.