Tech Founder $25M Exit: Succession for 3 Children Across 3 Jurisdictions
Background
Russian tech-company founder, successful $25M exit in late 2023. Three children: eldest daughter with German citizenship (21), son with British citizenship (17), youngest daughter with Russian citizenship (12). The founder is himself a Portugal tax resident under the NHR regime, which ends in 2027. Assets partly in crypto, partly in startup equity, partly in liquid instruments.
The Challenge
Succession must function across three legal systems: German forced heirship (Pflichtteil), UK inheritance tax, Russian FX regulation. Children of different ages and tax situations require different distribution rules. Crypto assets required dedicated structuring to satisfy bank and regulator requirements. The end of Portuguese NHR in 2027 required pre-emptive relocation of tax residency to a jurisdiction with a predictable long-term regime.
The Solution
- RAK ICC Foundation with a detailed distribution regulation: payouts conditional on age, education completion, and professional activity
- Separate IBC for crypto assets under VARA-compliant management
- UAE Golden Visa (exceptional talent pathway) for the founder and subsequent TRC
- Family charter with capital stewardship principles: values, investment philosophy, dispute resolution rules
- Independent foundation protector — a former partner of a Swiss law firm with German and UK client experience
Structures Used
- RAK ICC Foundation
- RAKEZ IBC
- VARA-compliant crypto wallet
- UAE Golden Visa
- Family Charter
Outcomes
“We needed a structure giving our children independence without breaking the family across different citizenships. RAK ICC delivered exactly that.”
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