Richard Branson moves assets from the U.S. to the British Virgin Islands, highlighting his use of tax havens while one of his businesses seeks a state bailout because of the coronavirus pandemic https://www.bloomberg.com/news/articles/2020-04-06/branson-shifts-1-1-billion-galactic-holding-between-tax-havens via @business

This is a great bit of digging, following up Branson's filing to amend ownership (as required by the SEC because of the public listing of Virgin Galactic Holdings, Inc). Details here: https://sec.report/Document/0001193125-20-076108/

As far as you can see, the substance of the matter is that Branson, declaring himself as a UK citizen, owns 58.6% of the (NYSE-listed) Virgin Galactic Holdings, Inc. - and this has not changed...

But the structure is quite another matter. Bear with me here...

First, Branson owns 100% of Virgin Group Holdings Limited, which is a BVI company.

Virgin Group Holdings Limited is the sole shareholder in Corvina Holdings Limited, which is another BVI company.

Corvina Holdings Limited is the sole managing member of Virgin Group Investments LLC, which is a Delaware entity.

Virgin Group Investments LLC is the sole shareholder in Virgin Investment Limited, which is another BVI company.

And Virgin Investment Limited has a 58.6% stake in Vieco 10 Limited, which is yet another BVI company.

Or something. Please correct me if I've messed up one of those steps.

The overall effect, in any case, it that the quite simple substance of the ownership has been very deliberately made complex and opaque, combining Delaware and BVI entities for no obvious reason.

It does rather raise the question, what does Branson stand to gain – or others to lose – from this arrangement?

As reported:
“This is an internal reorganization that has no effect on our ownership interest... Rather than continuing to hold the shares indirectly, we undertook this exercise to eliminate indirect ownership through that subsidiary, as the U.S. entity was no longer necessary”

Hard to see why so many BVI entities are still necessary though...

What investors may lose from this very complex structure is a clear line of sight, legally and in terms of the accounts of different entities, of their majority co-shareholder. Does that matter? Perhaps not, if everything goes right and everyone behaves themselves.

Generally, however, we find that the risks of things going wrong and/or of people not behaving as they should are, almost inevitably, exacerbated by both complexity and the opacity that comes with layering multiple legal entities from some of the most opaque jurisdictions.

Just for reference, here are all the latest reports from the Financial Secrecy Index and the Corporate Tax Haven Index, for the US and for the BVI
https://fsi.taxjustice.net/PDF/UnitedStates.pdf
https://fsi.taxjustice.net/PDF/BritishVirginIslands.pdf
https://corporatetaxhavenindex.org/PDF/BritishVirginIslands.pdf
https://corporatetaxhavenindex.org/PDF/USA.pdf 

While Branson reorganises his business in the aggressive corporate tax haven of the BVI, here's a shocking estimate from @_AfricanUnion "Overall, Africa could lose up to 20 to 30% of its fiscal revenue, which is estimated at 500 billion in 2019."
https://au.int/sites/default/files/documents/38326-doc-covid-19_impact_on_african_economy.pdf