Dr. Heitor Miguel
Attorney specializing in International Law
OAB/SP 252.633
About the author
Attorney registered with OAB/SP 252.633 (Brazilian Bar Association). MBA in Business Law and M&A from FGV. Specialist in International Law and iGaming. President of the International Law Commission of OAB/SBC. Deal Maker of the Year 2014 - IAE Awards.
LinkedIn profileAreas of expertise
- International Law
- International asset structuring
- International tax planning
- Mergers and acquisitions (M&A)
- Business Law
- iGaming
Published articles
Business Bank Account in Mexico: Where the Process Stalls
No Mexican law requires a Mexican apoderado — BBVA's digital channel does. See where that stalls, what it costs per year and when opening is not worth it.
26 SEP 2026 · 47 min read
Is an Exclusive International Fund Worth It in 2026?
An exclusive international fund costs US$ 55 to 150 thousand a year and lost its deferral under Law 14,754/2023. See the real math and when it still pays.
25 SEP 2026 · 20 min read
Opening a Company in Mexico: Complete Guide for Brazilians 2026
A Brazilian can hold 100% of the capital of a Mexican company, with no local partner, except for reserved activities. See company types, RFC, e.firma, RNIE and taxes.
22 AUG 2026 · 8 min read
How an Asset Holding Company Works: Assets, Taxes and Succession
Asset holding company in Brazil: how assets enter the company, what income tax it pays, how the donation of quotas is taxed and what it does not solve.
19 JUL 2026 · 12 min read
Family Holding in Brazil: Benefits, Costs and Setup Guide 2026
A family holding organizes succession during life and taxes rental income at 11.33% to 14.53% of revenue, below the individual's 27.5%. See what changed in 2026 with dividend withholding and Complementary Law 224.
19 JUL 2026 · 15 min read
Asset Protection From Creditors in 2026: What the Law Allows
Asset protection from creditors only works before the debt. See when a transfer becomes fraud in Brazil and what a Wyoming LLC, a Nevis trust and a holding protect.
17 JUL 2026 · 16 min read
Complete Offshore Setup: From Registration to Bank Account in 2026
The company is only the first of four steps. Incorporation, EIN, bank account and Brazilian filings, with official Delaware and Wyoming fees, Form 5472 and the end of the BOI report for U.S. LLCs.
30 JUN 2026 · 15 min read
Offshore Bank Account in 2026: Best Options
The right account depends on use: a fintech to run the LLC, a multi-currency account to receive payments and a traditional bank for custody. See documents and reasons for refusal.
27 JUN 2026 · 10 min read
How to Declare an Offshore on Brazilian Income Tax in 2026
The stake goes on Assets and Rights, income pays 15% on the Law 14,754 form, and passive controlled company profit is taxed every December 31. Here is the step by step.
21 JUN 2026 · 8 min read
Opaque vs Transparent Offshore: Legal Guide 2026
Understand the difference between an opaque and a transparent offshore under Law 14,754/2023: controlled entities, passive entities, profit taxation and the irrevocable art. 8 option.
20 JUN 2026 · 8 min read
Holding vs Offshore: Which to Choose in 2026? [Comparison]
A holding organizes control and succession in Brazil; an offshore serves assets, income and heirs abroad. Compare taxation, filings and limits of each structure based on the law.
17 JUN 2026 · 10 min read
Is an Offshore Legal? The Complete Legal Truth in 2026
Having an offshore is legal for a Brazilian resident if it is declared on the income tax return and to the Central Bank. See avoidance vs evasion, the fines and how to regularize.
16 JUN 2026 · 8 min read