@wellington
@Martin Everson
@pma995
As the replies on this matter are following my suggestion to OP that I can advice him on how to structure his ongoing affairs in ways to minimize taxes, I feel the urge to reply to the follow up comments. Although what is being said by Wellington and Martin is obviously valid, I believe that we are skipping the right of every individual to freely arrange his business dealings in such a manner to minimize taxes. This principle has been upheld by courts on numerous occasions, obviously with the caveat of transactions maintaining an economic/commercial rationale; something which is basically the principle upon which all anti-avoidance rules follow suit.
In this case, if my understanding is correct, OP has not disposed of its assets, therefore any tax implication has not yet materialized. At this particular point, it is the very right of the individual when considering the future of his finances to also consider options to structure them which can have a tax optimized result. Obviously he should always proceed to do that with openness and in accordance to the applicable laws and tax rules. Where the application of a particular tax rule falls within a grey area or where a different provision ( usually an anti-avoidance provision ) renders the application of a particular rule as "questionable", he should be able to comprehend the applicable risks and what they may entail in terms of "if things go sour" and the remoteness or not of that possibility. Mechanisms such as an advance tax ruling or a tax opinion can clear certain ground if it is deemed reasonable to proceed with one. In any event a negative outcome should never be a killer, i.e. landing him in jail, but in a worst worst case scenario should result in a civil procedure. Therefore a decision to go ahead with a particular arrangement should upheld a strong feeling of certainty to the individual up to the point where it should also be including a ready-ness of the individual to defend his position in front of the tax man or even in Court. Obviously the amount of taxes one may be saving from a particular arrangement is an additional consideration that should be included in his
risk assessment. Once the mentioned elements are there, then the individual is considered well informed to make a decision to go ahead with a particular route that could result into tax savings.
If OP, is still interested to chat, I would be happy to DM.