The following is a response to the previous Q&A on whether it's best
to own an investment in Panama forestry directly in the namer of the
ultimate owner or indirectly through a Panama corporation or foundation.

Vern

Panama has no estate tax and transfer tax is not levied in intestate
or testate transfers.

The reason the direct ownership is being offered may be that
ever-changing Panama immigration laws at some point granted permanent
residence as forestry investors only to those directly owning the land.

I believe in one of your previous emails you mentioned the Panama SRL
as an alternative to avoid CFC regulations. Great list! Keep those
emails coming. (Alvaro)

RESPONSE: The Panama S.A. entity is not eligible to elect to be a
foreign partnership (multiple owners) or disregarded entity (single
owner). The Panama SRL entity is apparently similar to a U.S. LLC and
is eligible to make the entity classification election, as is the IBC
form of entity. And, because the foundation form of entity is not
listed on the ineligible list, it is presumably eleigible to make the
entity classification election for U.S. tax purposes. (Vern)