International Tax Law

Job Description: We are a pre-revenue data-center and digital-infrastructure developer operating across the US and Chile. We are currently preparing for a capital raise at our holding company level (expected in ~5 months) and are formalizing our intercompany agreements and bridge financing structure. Our corporate structure consists of a US TopCo (Delaware LLC) holding USD founder capital, a Chilean OpCo (SpA) performing development work, and project-specific Chilean holding and SPV entities. We are looking for an experienced International Tax Professional—ideally with knowledge of both US and Chilean tax law, or a strong US international tax expert who can interface directly with our Chilean tax counsel—to review our proposed structure and answer specific tax compliance and efficiency questions. Scope of Work: Review our Intercompany Structure: We have drafted a 4-tier intercompany contract structure (Shared Services, Loan Facility, and Development Services agreements). Advise on US Tax & Structuring: Provide guidance on the founder member loan to the US LLC (including Applicable Federal Rates to avoid imputed interest), the tax treatment of the US LLC lending to a foreign subsidiary, and related-party transaction reporting (e.g., Form 5472). Advise on Cross-Border Withholding & Deductibility: Help us determine the most tax-efficient way for the US LLC to pay offshore vendors (e.g., Upwork engineering) directly on behalf of the Chilean OpCo. We need to confirm whether this avoids immediate Chilean withholding taxes and how to properly document these payments as loan drawdowns to ensure they remain deductible for the Chilean entity. Provide strategic recommendations: Review the planned repayment waterfall to ensure it aligns with our upcoming capital raise without causing issues with subordinated debt. What We Provide: I have attached a detailed "Tax Structure & Questions Brief" to this post that outlines our entities, the exact flow of funds, and the specific questions we need answered. We will provide the draft legal contracts (IC-01 through IC-04) upon hiring. Requirements: Active CPA (US) or equivalent international tax qualification. Deep expertise in cross-border intercompany transactions, transfer pricing principles, and foreign subsidiary funding. Familiarity with Chilean corporate tax law (Impuesto Adicional, Capítulo XIV FX registrations) is a massive plus, but not strictly required if you are comfortable collaborating with our local Chilean counsel. If you are interested, please review the attached brief and let us know your estimated hours to review the structure and answer these specific questions. Please review the post and if you are interested and meet the requirements please requestion an attachment with more details.