What the ledger is telling us
Exposure findings, risks and recommendations in one queue, ranked critical first. Every item opens on the facts it was derived from — nothing here is typed by hand.
sphera-wealth-management-advisory
Single-valley vineyard concentration exposes target to climate events
Top-5 customer concentration creates churn-revenue cliff
AEAT challenge on TFI substance carve-out for BVI vehicles
Form 5471 and 8621 filing complexity with potential IRS challenge on §962 election thresholds
Customer-concentration risk during integration (top-5 client retention)
Parental-gift letter from 2012 may not have contemporaneous corroboration; courts may reject as ex post facto
Pablo's premature death would expose 2.8M apartment to US estate tax above 60k exemption
FIRPTA 15% withholding on gross proceeds for any non-resident-held disposition
Bogotá-port corridor periodic disruptions impact revenue
COP/USD exposure on operating margins
Chilean tax reform may modify herencias schedule mid-plan
BVI ES Act breach if local director resigns and not replaced ≤ 30 days
Julia and Felipe may resist mandatory separation-of-property prenup clause
Failure to elect MTM/QEF triggers punitive excess-distribution regime
If equalisation paid, Colombian wealth-tax (Patrimonio) and AR/CL coordination on cross-border family payment
USD/MXN exposure on transaction price between LOI and closing
Spanish vecindad civil tests may challenge Elena's Catalan personal-law claim if Madrid residence is ever resumed
Recipient sells shares within 10-year retention window — empresa-familiar reduction clawed back
Inconsistency between agents on assumptions (e.g., FY24 EBITDA used in valuation vs in tax model)
UY 6-year territorial carve-out expires 2028; post-2028 worldwide income exposure
Family Council supermajority not achieved (Miguel might dissent on MX commitment grounds)
If Sofía later un-domiciles US (>8/15 yrs), §877A covered-expatriate exit tax applies
MX antitrust (COFECE) clearance for sub-100M deals is routine but adds 60-90 days
Felipe's worldwide assets exposed to ZH cantonal wealth tax
Founder mortality before staged plan completion would crystalise unplanned herencias liability
Risk that protocol conflicts with Andina Holding pact deadlock mechanism
MX REFIPRE re-characterisation if MX subsidiary income partially deemed passive
Rafael relocates from Madrid (loses 99% bonificación)