Case studiesPersonal
A founder's share sale, taxed once instead of twice
A secondary sale was in motion while the founder was moving between two countries. Both could claim the gain. We re-sequenced the move and the shareholding before anything was signed.
1.8USD m
less tax on a single disposal
- Client
- Software founder selling a minority stake
- Countries
- US · PT
- Timeline
- Eleven months from first brief to completion.
The situation
A secondary sale was already in motion while the founder was mid-move between two countries, still holding the shares personally.
Both tax authorities had a credible claim to the gain, and the move had been timed against neither one's residency test.
What we did
- 1Paused the sale timetable before the terms became binding.
- 2Re-sequenced the move against both countries' statutory residency tests.
- 3Reorganised the shareholding ahead of the sale.
- 4Agreed the filing position in writing with counsel in both jurisdictions before anything was signed.
The outcome
USD 1.8m less tax on the disposal, and a filing position both sides could support on paper.
Completed engagements are marked as such; examples marked "Illustrative" show how a typical situation is handled and are not client results. Names, sectors, figures and timings are generalised or omitted so that no client is identifiable. Every result depends on that client's facts. Nothing here predicts what your position would produce, and nothing here is advice.
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