Case study 1
A family investment company classified wrongly by its custodian
A holding company's account had been coded by its custodian on the strength of an incomplete form, and payments into it were being withheld on. The company had no financial business, but its classification on the custodian's records said otherwise. We worked through the classification properly, evidenced the ownership behind it, and lodged a certification the custodian would accept. The engagement produced a corrected status on the account, withholding stopped for payments made after it, and a documented basis the family can reuse when the next account is opened.
Case study 2
Which entity certifies when a corporate trustee holds the account
A trust's account stood in the name of a corporate trustee, and both the trustee and the trust had been asked to certify a status. Each had been waiting for the other. The work consisted of establishing who the account holder was for this purpose, who the controlling persons were, and which entity's classification the institution actually needed. The engagement produced one certification lodged by the right entity, a record of controlling persons kept with the trust's papers, and a note of what has to be refreshed when a trustee changes.
Case study 3
An operating company whose treasury function looked financial
A trading group ran cash management for its subsidiaries from one company, lending internally and taking deposits from them. On a quick reading of its accounts that activity resembled a financial business, and the classification originally certified reflected that reading. The work was to look at what the company actually does and for whom, rather than at the shape of its balance sheet. The engagement produced a re-determined classification, re-certification with each of the group's banks, and a short memorandum setting out the reasoning if the question is asked again.
Case study 4
An account left undocumented after the controlling persons changed
Withholding began on a company's account some months after a shareholder reorganisation. The institution had asked for refreshed controlling-person information, the request reached a director who had since left, and nothing was answered. We assembled the current ownership, re-certified the status, and explained the sequence to the bank's onboarding team so the account could be taken out of the undocumented category. The engagement produced a current certification, an account back in good standing, and a diary entry tying future certifications to changes in the share register.
Case study 5
Certifying one status consistently across several custodians
A holding company with owners connected to the United States had opened accounts with different custodians over the years, and each had received a slightly different answer to the same status question. Inconsistency is its own risk here, because the institutions report what they hold. We settled the correct classification once, with the ownership evidence behind it, then re-certified with each custodian to that same conclusion. The engagement produced one documented status, matching certifications on every account, and a single file the company uses when it opens the next one.
Case study 6
Settling classification before a fund account was opened
A newly formed investment vehicle came to us during formation rather than after withholding had started. We took the classification question as part of setting it up: what the entity would do, who would control it, who would own it, and therefore what status it would certify. The engagement produced the certification ready to hand the administrator at onboarding, the ownership evidence supporting it, and a note of the events that would require it to be revisited. No account was opened on an unanswered question.
Case study 7
Withholding Reduced by the Right Article
Dividends, interest and royalties each have their own article and their own rate, and the payer applies whichever it is satisfied of. Establishing entitlement before payment is what secures the lower rate at source.
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Case study 8
Which Country Taxes the Salary
The employment article turns on where the work is done, who pays, and who bears the cost — three tests that can point in different directions. The file establishes all three before either return is drafted.
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