PANAMA SOLAR — 12%, VIA A US PASS-THROUGH LEASEBACK
A vehicle purpose-built for American investors to capture Panama solar at 12% — with maximum US tax efficiency
The opportunity: a real, operating 150 MW solar project in Penonomé, Panama — in a USD economy, on one of Latin America's cleanest, sunniest grids. The vehicle: a US pass-through LLC buys the solar equipment and leases it back to the operator for a fixed 12% per year, paid monthly, in USD. American investors own a hard, producing asset — and get a tax profile no equity, fund, or dividend structure in Panama can match. Investment: $5–20 MM.
Location — Coclé province, Panama (Esri satellite).The operating Avanzalia array in the Penonomé cluster (Esri satellite). Exact target-parcel imagery + site photos to follow from the operator.
The project — Penonomé solar
150 MW solar under construction in Penonomé, grid-connected — with a ~150 MW pipeline behind it.
Panama = USD, no FX; abundant sun; among the cleanest grids in the Americas; pro-build, not pitchforks.
A real, revenue-producing hard asset — not a development bet. The 12% is tied to this operating energy asset, ring-fenced.
12,000 km of in-country fiber; the same asset anchors premium 24/7 power demand (sponsor upside — not your risk).
The vehicle — how it works
1 · US LLC buys A US pass-through LLC acquires title to the solar equipment.
2 · Leases back Operator pays 12%/yr, monthly, USD, under a true lease.
3 · Flows to you Rent and depreciation flow to investors' K-1s.
The headline for a US taxpayer: you collect 12% cash — and because your LLC owns the equipment, you depreciate it on your US return. On foreign-sited solar that's ~12-year straight-line (ADS), ≈8.3%/yr — which shields roughly two-thirds of the 12% rent, deferring that US tax across the depreciation period (recaptured at exit). Net: ~12% cash, only ~1/3 currently taxable for ~12 years.
Why this beats anything else you'd do in Panama — on tax
Depreciation shield (unique to ownership). Only owning the asset — via the leaseback — lets you depreciate it. Equity, preferred, a fund, or a loan give you none of this. ~2/3 of the rent shielded, tax deferred ~12 years.
No PFIC. You own equipment through a US LLC — not shares of a Panama corporation — so you sit entirely outside the punitive US PFIC regime that hits Americans who hold foreign-company stock.
Cleaner income. Your 12% is rent (ordinary income). With no US–Panama tax treaty, dividends from a Panama company are "non-qualified" — higher rates, no relief. Rent skips that.
Efficient in Panama too. The lease payment is deductible to the Panama operator (dividends aren't), so it's tax-efficient at the asset level as well.
Familiar US reporting. A US LLC → a K-1, not a foreign-entity filing maze. USD throughout, no FX.
