12% SALE-LEASEBACK — PANAMA SOLAR
A fixed 12% return, paid monthly, backed by ownership of operating solar equipment in Panama · USD
The offer in one line: you buy the solar equipment (a real, operating, hard asset in Panama) and lease it straight back to the operator for a fixed 12% per year, paid monthly, in USD. You own the asset; you are not buying shares of a company. Investment of $5–20 MM. The point of this note is simple: for US capital taking Panama exposure, a sale-leaseback is the cleanest possible structure — and by a wide margin the best-taxed one.
How it works — three steps
1 · Buy the asset
You acquire title to the solar equipment — a real, operating, revenue-producing hard asset.
2 · Lease it back
The operator leases it from you and pays 12%/yr, monthly, USD, under a true lease with defined term and buy-back.
3 · Own the downside
You hold title and repossession rights — senior and secured, not an unsecured bet on a company.
Why a leaseback — the tax case vs. anything else you'd do in Panama
- No PFIC. Because you own equipment — not shares of a Panama corporation — you sit entirely outside the US PFIC regime, the punitive tax that hits US investors who hold foreign-company stock. Buying Panama solar-company equity or preferred puts that PFIC risk squarely on you; a leaseback removes it.
- Cleaner income, taxed better. Your 12% is rent — ordinary income, straightforward. There is no US–Panama tax treaty, so dividends from a Panama company are "non-qualified" (taxed at higher ordinary rates, with no treaty relief). Rent skips that penalty entirely.
- You own a hard asset. Title to operating equipment with repossession rights — a senior, secured position — versus an unsecured equity or fund interest. Ownership economics (including any available equipment depreciation) accrue to you.*
- Tax-efficient on the Panama side. The lease payment is deductible to the Panama operator, so the structure is efficient at the asset level — unlike dividends, which are paid out of after-tax profits and are not deductible.
- USD, no FX. Panama is dollarized — dollars in, dollars out, with no currency exposure.
Head-to-head
| Structure | US PFIC? | Income taxed as | Secured? |
|---|
| Sale-leaseback (this) | No | Rent (clean) | Yes — own the asset |
| Buy Panama co. equity / preferred | Yes — risk | Non-qualified dividend | No |
| Lend to the Panama co. | No | Interest | Only if pledged |
| Foreign fund / token | Yes — risk | Varies / complex | Varies |
Terms at a glance
| Return | 12% / yr, paid monthly (fixed) |
| Structure | True sale-leaseback of solar equipment |
| You hold | Title to the asset (senior, secured) |
| Upside given away | None — non-convertible, no dilution |
| Investment | $5–20 MM · USD |
| Asset | 150 MW operating-stage Panama solar |
The asset
A 150 MW solar farm under construction in Panama (grid-connected, ~150 MW pipeline behind it), in a USD jurisdiction with 12,000 km of in-country fiber. The 12% is tied to this operating energy asset — ring-fenced — not to any development or venture risk.
*Depreciation and all US and Panama tax treatment are subject to the property's use, the true-lease characterization, and applicable law — to be confirmed with US and Panama counsel. This one-pager is a confidential summary for the named recipient; it is not an offer to sell or a solicitation to buy any security, and not tax, legal or investment advice. Any investment would be offered only to accredited/eligible investors under definitive documents containing full terms and risk factors, which control. The 12% is a fixed lease return dependent on performance of the underlying asset; capital is at risk. The structure is intended to qualify as a true lease and to be held through the appropriate vehicle for clean US reporting; both are subject to counsel. © 2026.