The Panamanian Private Interest Foundation

Two volumes in one edition. A complete treatise on the Panamanian private interest foundation and its international tax treatment.

The Panamanian private interest foundation remains one of the most widely used vehicles for asset protection, succession, and cross border structuring. Its treatment, however, has changed. Economic substance requirements, beneficial ownership registers, and the standards that keep Panama on the European Union list of non-cooperative jurisdictions have redefined how the foundation must be used. This edition brings both volumes together in a single reference: what the foundation is, and what now governs its tax exposure.

Written by Mauro Savino, an international tax lawyer based in Panama City with a decade of practice advising entrepreneurs, professionals, and internationally mobile families, the work moves from structure to substance.

The first volume examines the foundation as a legal institution: its civil law origins and Panamanian design; the foundation charter and regulations; the roles of the founder, the foundation council, and the protector; the position of beneficiaries; and the autonomy of the foundation patrimony. It sets the foundation against the corporation and the trust, and explains how creditor protection, forced heirship, purpose, and control are reconciled within a single structure. It also considers the practical uses of the vehicle: holding shares and real estate, organising family wealth, and providing for orderly succession.

The second volume addresses the questions that now determine outcomes: the economic substance rules and the conditions a qualifying entity must satisfy; the treatment of foreign source income under Panama's territorial system; beneficial ownership, the UBO register, and reporting under the Common Reporting Standard and FATCA; anti-abuse rules; permanent establishment risk; and Panama's tax treaty network. It then turns to the exposure of foundation holders under the law of their own countries, including controlled foreign company regimes, the United States framework of Subpart F, GILTI, and PFIC, and the positions in Canada, Latin America, and Europe.

Panama has moved from a model built on territorial exemption to one that requires demonstrable substance and transparency. The work explains what this means in practice for existing structures, the choices available to holders, and the planning that a compliant use of the foundation now requires.

A working reference for tax advisers, lawyers, accountants, wealth managers, family offices, and the entrepreneurs and international investors who rely on Panamanian structures. It assumes a professional reader and is organised for consultation as much as for continuous study.

Together, in one edition, the two volumes provide a complete account of the Panamanian private interest foundation: how it is constituted, how it is governed, and how it is taxed under the current international framework.