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U.S. LLCs Under Brazilian Tax Authority Scrutiny: What Changes for Brazilians with Offshore Structures
Recent Guidance Opinion (Solução de Consulta) COSIT No. 56/2026 has issued an important warning for Brazilians who invest or hold assets abroad through LLCs in the United States. In practical terms, the Brazilian Federal Revenue Service has consolidated its position that LLCs with non-U.S. resident members and treated as pass-through entities for U.S. tax purposes...
Approval of accounts in companies: a strategic moment for governance and alignment
In Brazil, it is common practice for companies to approve the accounts of their managers during the month of April, as, in most companies, the fiscal year ends on December 31. Accordingly, considering the legal requirement to deliberate within the four months following the end of the fiscal year, it is important to be mindful of the deadline for taking such action...
Choice of forum clauses after Law No. 14,879/2024: what has changed and the controversy over its application
Law No. 14,879, enacted on June 4, 2024, amended provisions of the Brazilian Code of Civil Procedure related to a common practice in both legal and business contexts: the so-called choice of forum clause. Traditionally, the Brazilian procedural system distinguishes between two types of jurisdiction for the exercise of judicial authority...
2026 Individual Income Tax Return: deadlines and the impact of asset reorganizations
