Description of the activity and instructions

You, as a tax advisor, receive a visit from a potential client: the CFO of an investment group, Mr$.$ Sergio Bejerano. His venture capital investment group has undertaken multiple international investments through one of the group's entities, a corporation named International Ventures Corp., with tax residence in Delaware.

The investments made include:

$$ The acquisition of $100\%$ of a Colombian company owning a solar farm. This company has paid two million dollars in dividends.

$$ The acquisition of $75\%$ of an Ecuadorian company owning a wind farm. This company has paid four million dollars in dividends.

$$ The acquisition of $100\%$ of a United States company owning an online payment platform. This company has paid one million dollars in dividends.

$$ The acquisition of $100\%$ of a company with tax residence in Hong Kong dedicated to holding activities. This company has paid twenty million dollars in dividends.

International Venture Corp. provides the following services:

$$ Financial advisory services, in terms of valuations, to a company with tax residence in Ecuador. The amount to be billed for such services is five million dollars.

$$ IFRS accounting advisory services for a company with tax residence in China. The amount to be billed for such services is one million dollars.

$$ Transfer of know$-$how to a company with tax residence in Colombia. For the transfer of know$-$how, it receives two million euros.

Considering the above, Sergio asks for advice on the following issues:

$$ The tax implications related to dividends, both in terms of withholdings and in terms of direct taxation at the level of the recipient.

$$ The tax implications related to income from services and transfer of know$-$how, both in terms of withholdings and in terms of direct taxation at the level of the recipient.

$$ The main consequence derived from the repatriation of capital when the income is subject to withholding in the source country.

$$ Would there have been any difference if International Ventures Corp. had been an S$-$corp?