Providing Structured Settlement Solutions
Structured Assignments, SCC was founded in 2010 as an entity for the purpose of accepting non-qualified assignments of periodic payment obligations. It is guided by an esteemed Board of Directors, utilizes the Royal Bank of Canada (the largest bank in the Caribbean) for all banking needs and was established with advice from the renowned law firm Chancery Chambers.
As a grandfathered Barbados International Business Company (IBC), Structured Assignments, SCC is subject to the relevant legal and regulatory authorities of Barbados. Additionally, since Structured Assignments, SCC conducts business with US clients, it has obtained U.S. IRS Tax Identification Number and is compliant with FATCA by obtaining its GIIN. The assignment company is domiciled and managed in Barbados in order to make use of the benefits of the US-Barbados Tax Treaty so that the ownership of the funding assets does not trigger double taxation.
An assignment company organized as a United States corporation would generally be subject to tax on the receipt of a payment for assignment of a periodic payment obligation (fee for services rendered) as well as any interest gain from the assets it purchased and owned. Further, it would not have any offsetting deductions upon the purchase of the funding assets until and as payments were made to the holder of the assets (e.g., as economic performance occurs). While there is an exception for this under Section 130 of the Internal Revenue Code, it is limited to periodic payment obligations that are tax exempt under Section 104(a)(1) or 104(a)(2) of the Code. Barbados is a highly regulated jurisdiction with a well-established and long-standing tax treaty with the United States that allows for the assignment of payment obligations and asset ownership in a tax efficient manner.
