Switzerland: canton, residence, banks and ownership structures
Three independent layers of any Swiss decision: the canton and the lump-sum regime, the federal residence permit, the bank and its booking centre. A cluster map.
Tax & investments
Tax regimes, investment transactions, CFC, ESOPs, secondaries and private capital. First identify tax residence and the applicable regime, then compare the instrument, the ownership structure and the timing of income recognition.
Start with the hubs
United States: Tax, Structures and Banking for Private Capital
US hub: US person status and substantial presence, pre-immigration planning, LLCs and trusts, the $15m estate exemption, 877A exit tax, EB-5 and banking.
United Kingdom: Tax, Banking and Structures for Private Capital
The UK after non-dom abolition: 4-year FIG regime, TRF to 2028, residence-based IHT after 10 of 20 years, SRT, banks from Coutts to fintechs, visa routes.
Sanctions: a Route Map for the Individual, the Bank and the Structure
Sanctions regimes as at 2026-08-28: the US 50% rule vs EU ownership/control, the 21st package, the Article 5b deposit cap, secondary sanctions, delisting.
The Investor: Capital, Status and Tax — Cluster Map
A map of the investor cluster: choosing the model of entry, the full price of a route, due diligence, the tax trail of a status, three regional maps and reform risk.
Where to Start: A Map of the wiki.private.law Corpus
Top-level index of wiki.private.law: three ways into the corpus - who you are, what happened, where you are - and routes to the tax, migration and capital hubs.
The Professional Athlete: Money, Visas and Tax — Cluster Map
Cluster map for the professional athlete: 183 days and centre of interests, OECD Article 17, 20% in the UK and 30% in the US, jock tax, image rights, visas.
Creators: Money, Visas and Taxes — a Cluster Map
The creator-economy hub: four income streams, platform withholding, DAC7 and CESOP, PSC vs holdco, relocation routes, talent visas and promo liability.
Taxes for private wealth: residence, special regimes and ownership structures
Hub for the tax section: three variables of the calculation, residence tests and exit tax, new-resident regimes, CFC rules, CRS, DAC8 and UBO registers.
Spain: visas, Beckham Law and taxes — cluster map
Spanish tax residency, the Beckham regime at 24% for six years, IP and ITSGF by region, Modelo 720, 2026 visa routes, property taxes and regional ISD rules.
Luxembourg: funds, holding companies and fintech licences
Luxembourg for private capital: RAIF and SIF funds under a third-party ManCo, SOPARFI participation exemption, PPLI insurance wrappers, tax and substance.
Russia: Relocation, Accounts, and Capital – What to Consider in 2026
Russia hub for private capital: the 183-day test and 13–22% scale, currency reporting, CFC rules, suspended tax treaties, personal foundations, payment routes.
Tax Residency: 183 Days, Centre of Vital Interests and the "Nowhere Resident" Myth
Why 183 days don't guarantee status, how OECD Article 4 tie-breaker works, why the "nowhere resident" myth is dangerous, and how residency connects to CRS.
Crypto for Private Wealth: Custody, Tax, Structures
How wealthy families hold crypto: multisig and MPC, qualified custodians, banking for crypto-origin funds, CARF exchanges from 2027, key succession.
U.S. tax residency
A practical guide to U.S. tax residency, citizenship-based taxation, FATCA, FBAR, CFC, PFIC, trusts, family offices, cleanup and expatriation for Americans abroad.
UK tax residence and worldwide taxation
UK tax residence, the FIG regime, worldwide income, offshore companies, trusts and funds, the TRF, CRS data and leaving the UK — the post-6 April 2025 frame.
Art and Collectibles as an Asset Class
Art cluster hub: the economics of collectible assets, title and provenance, freeports, AML, ownership structures and succession, with deep dives on tax, lending and the private museum.
Beckham Law: Spain's special tax regime
Spain's Beckham Law exempts foreign passive income and charges a flat 24% on employment income — worldwide, under Art. 93.2.b) LIRPF. Eligibility, the 6-year window and UHNW relocation.
What's inside
Country rules, instrument breakdowns and private-capital scenarios: option plans, secondaries, funds and joint investments, CFC rules and the reporting of foreign assets, from basic regime overviews to walkthroughs of specific transactions.
Beyond return
The outcome is set by more than the yield: the legal wrapper, liquidity, currency, the timing of taxation and the ability to transfer or sell the asset change the result more than a point of return.
Residence decides
The same deal produces different outcomes under a different residence, ownership route or funding source: fix your tax status first, and only then run the numbers on the deal. Relocating mid-deal can rewrite its economics retroactively.
Across the sections
An investment lives inside a structure and a tax regime: cross-check the sections on companies and funds and on banking — the wrapper and the account change the economics of the deal as much as the instrument itself.
Before you count
Rates and regimes change: check the date of the material and the primary sources. Price a specific deal together with an adviser — the section gives the frame of questions, not the final answer.
The catalogue is generated from the current Published corpus: a page appears here only when its public snapshot matches the active index revision, and archived or quarantined material is excluded. It is a research map, not individual legal, tax or investment advice.
Articles · 208
Fund Tax Architecture: Who Pays, Where and On What
The tax chain of an investment fund: asset and source country, transparent/opaque classification, feeders and blockers, three LP classes on one portfolio (UBTI, ECI, FIRPTA, §1446, PFIC), manager and carry.
Corporate Tax Residence: Incorporation, Management and Control, and Dual Residence
How corporate tax residence works: incorporation-based vs central management and control tests, board minutes vs substance of decision, dual residence and the post-2017 treaty rule, with an evidence matrix.
Entity Classification: Persons, Instruments and Income Across Borders
How each country decides whether an entity is a taxpayer or a look-through, an instrument debt or equity, and how ATAD 2 neutralises hybrid mismatches.
Permanent Establishment: Fixed Place, Agent PE and Treaty Thresholds
When a foreign company becomes taxable at source: how a permanent establishment is decided under domestic law and the tax treaty, fixed-place and agent PE, exceptions, and how profits are attributed.
Lending in China: rates, access and credit arbitrage
Cost of money in China, September 2026: LPR 3.00%, corporate loans 3.04%. Three access routes for non-residents, Sinosure terms, a $1m worked example.
Hong Kong: HKEX Listing and Dim Sum Bonds
Main Board, 18A, 18C, GEM and SPAC compared on thresholds, timelines and all-in cost — plus how dim sum bonds price against onshore CNY.
Panda Bonds
Who may issue panda bonds, which regulators clear them, timelines, coupons and the all-in issue budget, and how panda bonds differ from dim sum.
Shanghai Stock Exchange: SSE, STAR Market, GDR and the Bond Route
SSE Main Board and five STAR Market thresholds, the GDR route after the CSRC 2023 reform, and whether a foreign company can list in China.
Sinosure: Buyer Credit Limits, the Cost of Payment Terms and Subrogation on Default
How Sinosure credit limits work, what a supplier needs to grant 60–120 day terms, the true annualised cost of the delay, and what happens on default.
Advance Rulings in Singapore: What IRAS Confirms, What MAS Approves and Where Certainty Ends
How Singapore sells certainty in advance: the s.108 IRAS advance ruling, GST rulings, stamp duty adjudication, APAs, MAS 13O/13U approvals and EDB awards — with the published ruling corpus and the limits set by s.33.
Hong Kong vs Singapore Corporate Tax for a Trading Company: Which Is Lower in Practice
Two-tier 8.25%/16.5% against 17% with PTE, SUTE and the YA 2026 rebate: effective rates at six profit levels, FSIE both sides, Pillar Two threshold.
Singapore Holding Company with Founders in Europe: Where Does Management Live?
Singapore holding company with founders in Europe: where the operating company goes, why effective management decides residence (ITA s.2) and how EU CFC rules under ATAD treat the holding.
Singapore IP Company, UK-Resident Owner: The IDI Box Meets UK CFC Rules
IP in a Singapore company under the IP Development Incentive (5%/10%, ITA s.43X, nexus) with the family in the UK: UK CFC rules (TIOPA 2010 Part 9A), central management and control, substance.
UAE Holding Company for an EU Operating Business: Anti-Abuse, Beneficial Ownership, Substance
UAE holding over an EU operating business: 0%/9% corporate tax, participation exemption (Art. 23 FDL 47/2022), no Parent-Subsidiary shelter, GAAR and beneficial-ownership tests and real substance.
Hong Kong vs Singapore for Company Incorporation and Running Costs in 2026
Where to incorporate in 2026: Companies Registry and ACRA fees, Hong Kong's compulsory audit, Singapore's resident director and what the 2025 CSP Act changed.
Double Taxation Despite the Treaty: MAP, Arbitration and APAs
Mutual agreement procedure under OECD Model Article 25, MLI Part VI arbitration, EU Directive 2017/1852 and Russian Chapter 20.3: deadlines, odds and pitfalls.
Jersey Trust, Italian Family: Where Does the Holding Company Go?
Jersey trust with an Italian-resident family: where to place the holding, how CFC rules (art. 167 TUIR) and trust interposition read the stack, and why effective management must stay out of Italy.
Football Agents: Licensing, Fee Caps and the Litigation Against FIFA
FIFA agent rules: licence and exam, the 3-10% cap in art. 15, the EU Court ruling of 16.07.2026 and England without a cap — what applies on 07.09.2026.
Transfer of a Minor Footballer: RSTP Article 19 and Its Exceptions
The ban on international transfers below 18, the five exceptions in RSTP Article 19, the TMS minor application, Football Tribunal deadlines, Brexit and club sanctions.
Relocation Matrix: Leaving One Jurisdiction and Entering Another
Twelve jurisdictions from both sides: when the old residence breaks, what the exit costs, what trails behind and how the new one arises. Pair: country A's exit column plus country B's entry column.
Children in Content: Earnings, Consent and Safeguards
France, California, Illinois, Minnesota and Utah: when a parent must obtain a permit, place the child's share in trust and erase the content once the child turns 18.
Hong Kong's Tax Treaty Network
Hong Kong's CDTA network as at August 2026: 51 in force, 8 signed, 17 in negotiation. Withholding rates, Certificate of Resident Status in 21 working days, MLI reservations, CARF and Pillar Two.
Ambassador Liability for the Promoted Product
Who pays when the promoted product is empty: section 17(b), blue-sky claims, 16 CFR 255.1(e), FSMA 2000, article 56 of China's Advertising Law, EU 2024/2853.
Gambling Sponsorship: What Clubs, Leagues and Ambassadors May Do
Gambling ad bans in Italy, Spain, Germany, the Netherlands and the UK: shirts and boards, broadcast windows, the strong appeal test, fines and transitions.
Right of Publicity and AI: Deepfakes, Voice and Post-Mortem Protection
Digital replicas of voice and likeness: the ELVIS Act, AB 1836 and AB 2602, NY § 50-f, NO FAKES, AI Act art. 50 and the Danish model — terms, penalties, take-downs.
Esports: Visas, Prize Money and Withholding
An esports player has no federation to endorse them: § 22 Nr. 5 BeschV with the ESBD, the French employer approval, no UK route, Article 17 against Articles 7 and 15.
CPF in Singapore: Who Contributes, the 2026 Rates, and What Happens When You Leave
Singapore CPF in 2026: 37% for those 55 and below, the S$8,000 OW ceiling, graduated PR rates, retirement sums, CPF LIFE, SRS and closing the account on exit.
Singapore GST: The 9% Rate, Registration Gates, Zero-Rating and Exemptions
Singapore GST in 2026: the 9% rate, the S$1m registration tests, reverse charge and OVR for holdings and funds, zero-rated against exempt, filing and penalties.
ERA: Exempt Reporting Adviser in the United States
What is an Exempt Reporting Adviser, how ERA differs from RIA, how venture-capital and private-fund adviser exemptions work, and what events trigger registration.
RIA: Registered Investment Adviser in the United States
What is a Registered Investment Adviser, when managers need SEC or state registration, how Form ADV works, and how RIA differs from ERA, broker-dealer, and family office.
Sentenor Bank: Dominica Offshore Bank
Sentenor Bank Corporation, a 2025 Dominica offshore bank: FSU licence, products, onboarding, client-money protection, crypto status and what stays undisclosed.
Image Rights: The Persona as a Tax Structure
Article 92 LIRPF and the 85/15 rule, the Ancelotti conviction of 09.07.2025, HMRC after Hull City, the Guernsey register at £500 and the 65/35 split in Garcia.
The UK for a Foreign Sportsperson: Duty Days and Global Endorsements
How the UK taxes visiting athletes: 20% FEU withholding above £12,570, RPD and RPTD allocation of global endorsements, and image rights PAYE from April 2027.
The OnlyFans Economy: Why the Platform Pays the VAT for Everyone
Fenix International (C-695/20): the platform pays VAT on the fan's whole payment, not on its 20% cut. What is left to the creator: registration, 1099s, DAC7.
Tax Residence on Tour: How the Authorities Prove You Never Left
How the authorities rebuild a touring year: CRS, DAC7 and the PStTG, the Shakira ruling, BFH case law on § 8 AO, and the residence certificate procedure in Spain, Germany, the UAE and Andorra.
Who Sees a Creator's Income: DAC7, MRDP, 1099-K and CESOP
No threshold under DAC7 for personal services, UK MRDP from 2024, the 1099-K threshold back at $20,000 and 200 transactions, CESOP from 25 payments a quarter.
Getting Paid After You Move: Ohtani, Bonuses and RCAs
4 U.S.C. § 114 and Ohtani's $680m: how a deferred payout escapes state tax, where § 409A and § 457A bite, and what the Tavares dispute with the CRA turns on.
Spain and Professional Athletes: The Beckham Law Is Closed — What Replaces It
Professional athletes are excluded from the article 93 LIRPF regime by RD 1006/1985. Rates of 24/47%, Madrid's 20% deduction and the 85/15 image rights rule.
NIL in 2026: Revenue Sharing, Deal Clearing and the F-1 Deadlock
House v. NCAA: a $20.5m cap per school in 2025/26 and $21.3m in 2026/27, deal clearing from $600, self-employment tax and the F-1 deadlock for foreign athletes.
Regulating Info-Products and Influencers: Advertising, Registers, Liability
Rules for info-products and creators compared: ad disclosure (FTC, CAP Code, DSA, erid), registers in Russia, Spain, Italy and the UAE, fines from 6% and 10% of turnover to criminal cases in Russia.
Golden Visas and Tax Residence: Status, Presence and Tax Exposure
Where an investor residence permit changes nothing (Portugal, Greece), where municipal registration is the trigger (Italy) and where the card itself is residency (US).
Article 17 of the OECD Model: Tax Where You Perform
Withholding on performers and athletes: 20% in the UK, 30% in the US, treaty thresholds of $10,000–20,000, event exemptions and the Monaco and UAE dead end.
Platform Withholding: YouTube, Twitch and TikTok
How YouTube, Twitch and TikTok withhold US tax: 30% on the US share, up to 24% without a W-8BEN, and why Russian residents lost the treaty rate in 2024.
The United States for a Foreign Athlete: 30%, CWAs and the Jock Tax
30% of gross under §1441, a CWA filed 45 days before the event, jock tax on duty days, Pittsburgh's 3% struck down on 25.09.2025 and the World Cup formula.
Borrow Against a Collection or Sell: Tax, Cost and Risk
Interest on art loans is non-deductible under §163(h), with no carryforward. Break-even is 5 years versus 7.5 for an SBLOC. Maths, §68 from 2026, collateral.
Situs of Movable Assets: Aircraft, Yachts and Collections
Where a jet, yacht or painting sits for inheritance tax: the US $60,000 threshold, the UK long-term residence test, French assiette matérielle, treaties.
Personal Use of Corporate Assets: Benefit-in-Kind for Aircraft, Yachts and Property
How personal use of a corporate jet, yacht or villa is taxed: US SIFL, the UK 20% rule, French valeur réelle, Spain's TEAC criterion and Russian art. 211.
Mortgages for Non-Residents: LTV, Rates and Eligibility by Country
Regulatory LTV caps, August 2026 rates and lender criteria for non-resident borrowers across eleven jurisdictions, from Spain and Portugal to the UAE.
Withholding Tax: Source, Rates and Treaty Relief
The invisible tax on cross-border income: how withholding works on dividends and interest, treaty rates and W-8 forms, beneficial owner, FASTER from 2030.
Luxury Taxes: ATED, Superbollo and Immobile Tax Bases
Why luxury taxes keep getting repealed: the 1991-93 US failure, the UK's ATED, Italy's superbollo and Canada's 2025 repeal for jets and yachts.
Private Museum and Charitable Foundation: Collection Ownership and the FMV Deduction
Private operating foundation §4942(j)(3): full fair market value deduction, 30% AGI ceiling, related use, self-dealing under §4941 and the 0.5% floor from 2026.
Private Aircraft Tax: Bonus Depreciation, VAT and Personal Use
100% bonus depreciation after OBBBA, the §280F, §274 and §469 tests, 2026 SIFL rates, EU input VAT recovery and the capital goods scheme, benefit in kind across four jurisdictions.
Capital Gains Tax: Basis, Realisation and Buy-Borrow-Die
How capital gains tax works and why realisation is the operative word: rates by country, step-up basis, buy-borrow-die mechanics, exchange funds and exit taxes.
Capital Gains on Art and Collectibles by Country
US 28% plus NIIT, Germany nil after a year and a day, France 6.5% of price, UK wasting assets, Switzerland and Italy judged on the seller's conduct.
Wealth Tax by Country: Tax Base, Rates and Exemptions
Where wealth tax still bites in 2026: Spain's IP and ITSGF, Norway's formuesskatt, Swiss cantons and France's IFI. A €10M worked example plus mitigation.
Trust Taxation: Grantor, Non-Grantor and Russian Rules
How tax systems see a trust: US grantor vs non-grantor, throwback and Form 3520, UK relevant property after FIG, Russian CFC rules and CRS transparency.
Venture Tax Reliefs: QSBS, EIS/SEIS and Opportunity Zones
The relief map for founders and angels: tiered QSBS ($15M cap, 3/4/5-year holds), the UK's EIS/SEIS through 2035, permanent Opportunity Zones from 2027. How they combine and where the limits are.
Art Taxation: Donations, Dation en Paiement and Freeports
Tax treatment of art collections: US FMV charitable deductions, UK Acceptance in Lieu, French dation en paiement, freeport customs suspension, fractional gifts, insurance proceeds and valuations.
Charitable Deduction: Appreciated Stock, CRT/CLT and DAFs
The charitable deduction after the 2026 rewrite: the 0.5% AGI floor, the 35% cap, the $1,000 non-itemizer deduction, appreciated stock, DAF bunching, CRTs and CLTs — what works now.
Art as an Asset: Title, Provenance, Storage and Lending
The legal mechanics of owning art: title and provenance, UNESCO and UNIDROIT, Nazi-era restitution, art-secured lending, export control and AML.
Pension Assets on Relocation: SIPP, QROPS, 401(k) and the Destination Country
What happens to pension savings when residency changes: SIPP relief, the 25% Overseas Transfer Charge, 401(k) and IRA, UK IHT from 2027, destination regimes.
Fund Secondaries: LP-Led, GP-Led and Continuation Vehicles
LP-led and GP-led fund secondaries: continuation fund mechanics, status quo option, fairness opinions, conflicts of interest, and 2025-2026 market data.
Buying Property in the UAE as a Non-Resident: Freehold, DLD and Residence
Freehold zones in Dubai and Abu Dhabi, a 4% DLD fee, no annual property tax, Golden Visa from AED 2m, off-plan escrow and DIFC wills. The non-resident deal.
Family Investment Policy: IPS, Powers and Investment Committee
What belongs in a family IPS, how an investment committee governs policy, what the prudent investor rule demands, and why rebalancing beats manager selection.
CARF: Crypto-Asset Reporting and First Exchanges in 2027
CARF in practice: who is an RCASP, which exchange and transfer aggregates are reported, why wallet balances are not, the 2027/2028 waves, DAC8 and 1099-DA.
Buying Property in Greece as a Non-Resident: Law, Taxes and Golden Visa
Entry at 3.09% instead of 24% VAT through end-2026, Golden Visa from €250,000 to €800,000, ENFIA and the Athens Airbnb freeze — and an opaque holding pays 15% a year.
Buying Property in Cyprus as a Non-Resident: VAT, Transfer Fees and Title Deed
A Cap. 109 permit and a 4,014 sq m cap, transfer fees of 3-8% halved, 5% VAT only for a main residence, PR from EUR 300,000. The 2026 reform scrapped stamp duty and SDC on rent.
Russia to the UAE vs Russia to Singapore: The Tax Mechanics of Two Relocation Routes
Russia to the UAE vs Singapore in 2026: 0% vs 24% personal tax, the QFZP de minimis trap, Golden Visa vs Employment Pass, bank onboarding and CFC lock-in.
Singapore Personal Income Tax: Rates, Reliefs and Non-Resident Rules
Singapore personal income tax for YA2026: resident scale 0–24%, non-residents 15% or 24%, S$80,000 relief cap, SRS, IR21 clearance, foreign income exemption.
Hong Kong vs Singapore for a Trading Company with Mainland China Clients
Hong Kong or Singapore for China trade: profits tax 8.25%/16.5% vs 17%, China DTA withholding, around 75% vs low single digits offshore RMB clearing.
Singapore Capital Gains vs Trading Income: The Badges of Trade
No capital gains tax in Singapore, but IRAS taxes trading: badges of trade, s.13W safe harbour (20%/24 months), s.10L foreign gains and SSD on flips.
Certificate of Residence in Singapore: Who Needs It and How IRAS Issues It
Singapore CoR: control and management test, the 50% board rule, CY2025 rules for foreign holdings, myTax Portal in 7 working days, refusals and treaty forms.
Foreign-Sourced Income in Singapore: What Individuals Pay When Money Arrives
Foreign income of individuals in Singapore is exempt under s.13(7A) ITA: partnership carve-out, remote work and director's fee traps, corporate FSIE contrast.
Singapore's 60-Day Rule: Short-Term Work and the Tax Exemption
Section 13(6) ITA: 60 days of non-resident employment tax-free. Carve-outs: directors (24%), entertainers, professionals (15%); 61-182-day band; remote work.
Sanctions-Resilient Structures in 2026: The Mechanics for Russian Capital
Surviving compliance shocks without circumventing sanctions: the 50% rule in the EU, OFAC and the UK, Article 5b, EU packages 19 and 20, stress tests.
CFC and PFIC Rules Stacked: A US Person with EU Residence and an Offshore Company
How CFC and PFIC read one foreign company: the §1297(d) ordering rule, OBBBA parameters from 2026 (NCTI, 40% deduction, §958(b)(4)) and the exits that work.
Hong Kong Salaries Tax for Remote Workers: Foreign Employers and the 60-Day Rule
Goepfert and where the employment sits, s 8(1A) day apportionment, the 60-day rule after So Chak Kwong, directors' fees, dual contracts and the 183-day article.
Hong Kong Tax Residence and the Certificate of Resident Status
Territorial tax, the IRD test (ordinarily resides, 180/300 days), the Certificate of Resident Status in 21 working days, 51 treaties, and the CRS bank form.
Hong Kong Company, Singapore Resident: Who Taxes What
Keeping a Hong Kong company as a Singapore resident: offshore claims and FSIE in HK, the control-and-management test (SG 17%), and the salary trap.
Taxes in Serbia
Serbia taxes 2026: 10% salary tax, 35% contributions, 15% dividends and capital gains, annual surtax 10-15%, pausal regime, 50% crypto relief, Russia treaty.
Exiting Spain's Beckham Regime: Timing, Renuncia, Exit Tax
Six tax periods, renuncia in November–December and exclusión within a month: the tax cliff after the regime, and the exit-tax window under art. 95 bis.8 LIRPF.
Spanish Wealth Tax: IP and the Solidarity Tax ITSGF
Spain's IP at 0.2–3.5% and the ITSGF up to 3.5%: the €700,000 allowance, the 2026 regional map, the foreign-structure trap, and the 60% cap for non-residents.
New Zealand: Investor Residency, No-CGT Taxes and Citizenship
Active Investor Plus residency (NZD 5m, 21 days of presence over 3 years), citizenship in 5 years, taxes with no CGT or inheritance tax, the 4-year exemption and the year-five FIF trap.
Milei's Argentina: Residency, Two-Year Citizenship and Taxes
Argentina 2026: rentista and nomad statuses, the constitutional two-year citizenship (and the 2025–2026 decree war), Bienes Personales → 0.25%, REIBP and Milei's reforms.
Securities Custody: Euroclear, Clearstream, Pershing
How securities custody works: the custody chain, CSD and ICSD depositories (Euroclear, Clearstream), global custodians and Pershing, asset segregation and sanctions risk.
Foreign Real Estate Purchase for Non-Residents: Rules, Taxes, Structures
London, Italy, France, Portugal, Spain, Singapore, Bulgaria, Austria, UAE, Greece, Cyprus: what non-residents need, entry tax from 2% to 60%, residency by purchase and ownership structuring.
Buying Property in Bulgaria as a Non-Resident: Apartments Without Land, EOOD, and Residence Permit for €307,000
Apartments in Bulgaria are available to any nationality, land only through Bulgarian EOOD. Euro from 2026, Schengen from 2025, residence permit for purchases from 600,000 BGN.
Buying Property in Austria as a Non-Resident: Grundverkehr, Regional Permits, and Vienna
For non-EU buyers, each Austrian state requires Grundverkehr approval: Vienna is feasible, Tyrol nearly closed. 3.5% GrESt, 2025 share-deal reform, 30% ImmoESt, zero inheritance tax.
Buying Property in Spain as a Non-Resident: NIE, Regional ITP, and the End of Golden Visa
NIE requirements, military zones for non-EU buyers, ITP from 6% in Madrid to 13% in Catalonia, the fate of the "100% tax" and golden visa, ownership and sale taxes—a guide for non-residents.
Buying Property in Singapore as a Foreigner: 60% ABSD and Residential Property Act
Foreigners can buy condos freely, landed property requires LDAU approval. 60% ABSD for foreigners, FTA exceptions, SSD on early sales, and why structures don't work.
Buying Property in Portugal as a Non-Resident: NIF, 7.5% IMT and What's Left of the Golden Visa
From 25 May 2026, Portugal charges a flat 7.5% IMT on non-residents. NIF and fiscal representative, CPCV and escritura, AIMI, golden visa fate and D7/D8 routes—explained.
Buying Property in France as a Non-Resident: Notaire, SCI and IFI
France imposes no restrictions on foreign buyers: transactions through notaire with costs ~7–8%, IFI on property over €1.3m, SCI for inheritance, réserve héréditaire and exit taxes.
Pillar Two: Global Minimum Tax 15%
How the OECD global minimum tax works: €750m threshold, QDMTT/IIR/UTPR, safe harbours, side-by-side for the US, and what it means for private structures.
Purchasing London Property as a Non-Resident: SDLT, ROE and Inheritance Tax
No restrictions for foreigners, but SDLT with 5% + 2% surcharges reaches ~17%, companies pay ATED and disclose in ROE, and UK property always faces 40% IHT. Transaction breakdown.
Buying Property in Italy as a Non-Resident: reciprocità, codice fiscale, and Taxes
How non-residents buy property in Italy: reciprocità check (confirmed for Russian citizens), codice fiscale, 9% registration tax on cadastral value, IMU, rental, and inheritance.
IP Box: Preferential Tax on Intellectual Property and the European Meta
How IP box regimes work: modified nexus under BEPS Action 5, effective rate map (Ireland KDB, Cyprus, Netherlands, Luxembourg), and regulatory passporting in the EEA.
Special Tax Regimes for New Residents: A Map of Options
A map of special tax regimes for changing tax residency: non-dom, flat tax, territorial taxation, and tax holidays. How to choose and where the pitfalls lie.
Tax Transparency: CRS, FATCA and the End of Banking Secrecy
How automatic tax information exchange works: CRS and FATCA, crypto exchange CARF from 2027, UBO registers and DAC6 scheme disclosure. What it means for private wealth.
Private Investor Infrastructure: A Map of Platforms for Family Offices
A map of private investor infrastructure: private equity (Moonfare, iCapital), pre-IPO secondaries (Hiive, Forge, NPM), SPV and cap table (Carta, AngelList, Sydecar) and crypto custody.
CFC (Controlled Foreign Company): Master Guide to Regimes and Residency Strategies
Comprehensive master guide to CFC (Controlled Foreign Company) rules: core regimes (Russia, US GILTI, UK TIOPA, EU ATAD) and mitigation strategies through tax residency planning.
Carried interest 2026: the jurisdiction map for fund principals
Carried interest in 2026: the UK moves it into trading profits (34.1%/47%) and reaches non-residents, Luxembourg offers 11.45% or exemption, Italy 26%, France 31.4% PFU, the US keeps § 1061.
Investor Onboarding in a Fund: From Qualification and KYC to LPA and Capital Call
Complete guide to entering a fund: accredited investor and qualified purchaser qualification, KYC and source of wealth, tax forms W-8BEN/W-9, subscription agreement, LPA, and capital call mechanics.
Solicitor — English Lawyer for Private Capital
Solicitor in the English tradition: reserved activities, legal professional privilege, client account, undertakings, trust practice, and recognition of status outside England.
Accredited and Qualified Investor: Rules and Thresholds
Access regimes to private markets: accredited investor in the US, professional client in the EU, qualified investor in Russia—thresholds and qualification methods.
Financing in China: trade finance, Sinosure and RMB payments
How trade finance works in China: letters of credit, Sinosure cover, export buyer's credit and RMB settlement via CIPS, and what banks verify.
Sydecar: Turnkey SPV with Fixed Pricing and No Carry
Fixed-price SPV with no carry: standardized documents, fast club deal launch, format limitations. Alternative to AngelList for deal leads who want to keep upside.
Fireblocks: The Infrastructure Behind Everyone Else
MPC wallets, policy engine, and transfer network powering exchanges and banks; how family offices use Fireblocks indirectly through their custodians and managers.
Kraken: regulation, custody and institutional services
Kraken: trading, Prime, OTC, staking and custody through Kraken Financial. Regulatory entities, Wyoming SPDI status, asset protection, onboarding and limits of public insurance disclosure.
Masterworks: How to Buy a Share in Banksy Without Buying the Painting
Securitization of paintings through SEC-registered offerings: fees, secondary market, actual returns, and risks of fractional art investment.
Coinbase Prime: Crypto Prime Brokerage of a Public Company
Custody, execution, and financing within a public company framework: how Coinbase Prime works and who it suits for institutional digital asset management.
AngelList: How a Family Office Runs "Club" Deals
How family offices use AngelList to run syndicates: deal-by-deal SPVs, fund administration, banking, and platform fees. Infrastructure for direct venture investing.
Nasdaq Private Market: Company-Sponsored Liquidity
Tender buybacks and company-sponsored liquidity programs: how NPM organizes transactions for employees and early investors in late-stage private companies.
Moonfare: private equity for those without $10M for a single fund
How Moonfare opens access to private equity funds through feeder structures: minimum checks, secondary windows, fees, and intermediary risks explained.
iCapital: The Alternative Investment "Plumbing" You Don't See
The B2B platform through which banks and advisors distribute PE, private credit, and hedge funds: feeder funds, document flow, and technology stack.
Hiive: Order Book for Private Company Shares
Order book for pre-IPO: direct matching of buyers and sellers of private company shares, transparent quotes, and investor access.
Forge Global: Full-Stack Secondary Market—Now Under Schwab
Full-stack private equity secondary market—brokerage, custody, Forge Price data; the Charles Schwab acquisition and what it changes for accredited investors.
Carta: Cap Table Management, Fund Administration, and a Data Privacy Lesson
How Carta became the industry standard for cap table management and fund administration, and why it exited secondary trading after a 2024 data scandal.
Anchorage Digital: Crypto Custody Under Federal Banking License
First crypto bank with federal OCC charter: asset segregation, staking from custody, governance tools for funds and family offices.
Suspension of Tax Treaties by Russia: Consequences
Presidential Decree No. 585 of 08.08.2023 suspended tax treaties with 38 countries: payments from Russia at Tax Code rates, US mirror response, double taxation, and new UAE treaty.
Capital Amnesty in Russia: Four Waves of Voluntary Disclosure
Four stages of voluntary disclosure under Federal Law 140-FZ: special declaration, repatriation and redomiciliation to SAR, guarantees of immunity, and current status.
Stablecoins: Types and Regulation
Stablecoin regimes in 2026: MiCA in the EU, the GENIUS Act in the US, HKMA licences in Hong Kong, final FCA rules, plus risks and tax for private holders.
Voluntary Disclosure and Capital Amnesties
How voluntary disclosure works: willful vs. non-willful violations, US VDP and Streamlined procedures, the role of CRS and FATCA, penalty reduction and criminal risk mitigation.
Multi-Currency Management and FX Hedging of Capital
Managing capital currencies: choosing a base currency, currency risk, natural hedging, forwards and options, FX market context and typical costs.
GAAR and Principal Purpose Test
How GAAR and principal purpose test work after BEPS: ATAD Art.6, MLI Action 6, substance over form principle and real substance requirements.
Swiss lump-sum taxation: expenditure basis, control calculation and permit limits
Swiss expenditure-based taxation: how the lump-sum regime is calculated, control thresholds and permit limits for wealthy foreigners relocating private capital.
AML/KYC for Private Clients
How AML/KYC works for high-net-worth clients: CDD and EDD, source of funds and source of wealth, PEP status, FATF standards, and EU reform with AMLA.
Structured Products and Notes: How They Work and What the Risks Are
How structured products and notes work: capital protection, autocall and reverse convertible, issuer credit risk, liquidity and PRIIPs KID / MiFID II regime.
Crypto Taxation by Country
Three models of crypto taxation: zero capital gains (UAE, Singapore), holding-period exemption (Germany, Portugal), and full taxation. The role of residency and CARF.
ESOP guide — How stock option programs work
How employee stock option plans (ESOP) work: option types, vesting, tax treatment and practical use. A founder and family-office view across jurisdictions.
What is a Fund of Funds?
How a fund of funds works: an LP buys a stake in a fund that holds many PE or venture funds — the diversification math, the double fee load, and when it makes sense.
International Brokerage Account: IBKR and Alternatives
International brokerage accounts (IBKR and alternatives): access to global markets, multi-currency functionality, margin, SIPC and FSCS protection, CRS/FATCA reporting, and tax considerations.
Split-year treatment: tax year of relocation to the UK
How UK split-year treatment divides the tax year of relocation into UK and overseas parts: eight SRT cases, automatic application, and common pitfalls.
El Salvador: Bitcoin and Freedom Visa
Bitcoin in El Salvador after the IMF deal and the Freedom Visa program: citizenship for $1 million in BTC or USDT, limits, and status as of 2026.
Tie-breaker: Dual Tax Residency and Its Resolution
How dual tax residency is resolved: tie-breaker sequence under OECD Model Convention Article 4—permanent home, centre of vital interests, habitual abode, nationality, MAP.
How National Security Review works
What national security review actually tests: investor chain, sector, stake and governance rights. CFIUS, UK NSIA and German AWV triggers, filings before closing and post-closing risk.
MiCA: EU Single Regime for Crypto-Assets
How MiCA works: ART and EMT token categories, CASP license and passporting, rollout stages and transitional period until 1 July 2026.
Mexico: Residence and Taxes
Mexico residence: temporary and permanent status, economic solvency requirements, worldwide income taxation for tax residents, and the center of vital interests test.
Bermuda: Residence and Zero Taxes
Bermuda residence through Economic Investment Residential Certificate: investment from $2.5 million, 90 days per year, and a regime with no income, inheritance, or wealth tax.
Capital Call: mechanics of capital calls in funds
How a GP draws uncalled commitments from LPs: capital call mechanics, notice periods and default remedies in PE and VC funds, for private-capital investors.
Costa Rica: Residence and Territorial Tax
Costa Rica residence: rentista, inversionista and pensionado programs, income and investment thresholds, territorial tax system and path to permanent residence.
Israel: 10-Year Exemption for New Immigrants
Tax benefits for new immigrants to Israel: 10-year exemption on worldwide income, removal of reporting exemption from 2026, and new two-year incentive for olim.
Channel Islands and Isle of Man: Residence and Tax Caps
Jersey, Guernsey and Isle of Man for high-net-worth residents: 20% income tax, tax caps, high value residency regime, and no capital gains or inheritance tax.
Liechtenstein: Residence and Taxes
How Liechtenstein residence works: quotas and lottery for residence permits, income and wealth tax, lump-sum regime for ultra-high-net-worth individuals, and no capital gains tax.
Andorra: Tax System and Residency
Andorra's tax system: income tax up to 10%, VAT 4.5%, no wealth or inheritance tax, passive residency conditions, and CRS compliance explained.
Monaco: Tax Regime for Residents
How Monaco's tax regime works: zero personal income tax, French citizens exception under the 1963 convention, inheritance tax, and residency requirements.
CFC: declaration of controlled foreign companies
How controlled foreign company (CFC) rules force tax residents to declare and pay tax on foreign income: filing duties, thresholds and cross-border wealth risks.
Upstream basis step-up: erasing built-in gain through the older generation, cross-border too
How IRC §1014 resets the basis of inherited assets to date-of-death value, why the step-up reaches a nonresident alien's foreign assets (Rev. Rul. 84-139) and where the §1014(e) one-year rule bites.
DAC6: Mandatory Disclosure of Cross-Border Arrangements in the EU and Hallmarks
EU Directive 2018/822 (DAC6): who discloses cross-border tax arrangements and when, five categories of hallmarks, and the role of the main benefit test.
Tokenization of Real-World Assets (RWA) and Stablecoins: Digital Wrapper for Real Assets
What legal right an RWA token contains: five models from direct statutory rights (TVTG, Swiss DLT Act) to SPV shares (BUIDL), issuer claims (xStocks), beneficial interests (PAXG) and synthetic exposure — with a rights matrix and failure scenarios.
Precious Metals Vaults and Freeports: Allocated Storage, LBMA, and Free Ports
How to store precious metals: allocated vs unallocated storage, LBMA Good Delivery standard, freeport storage in Switzerland, Singapore, and Luxembourg, tax benefits and costs.
Lombard Lending: Liquidity Against Portfolio Collateral
How lombard lending works: pledging portfolios without selling, loan-to-value (LTV) by asset class, floating rates, margin call risk, pledge versus title transfer and interest deductibility.
PPLI: Private Placement Life Insurance as a Portfolio Wrapper
How PPLI works: tax treatment, §817(h) diversification test, investor control doctrine, qualified purchaser, jurisdictions (Luxembourg, Bermuda), and CRS transparency.
Substance: economic presence requirements
Economic substance rules for offshore structures: real-presence tests, reporting and why paper companies now fail. Practical view for cross-border holding owners.
Roth abroad: the one US wrapper that survives relocation
Qualified Roth distributions stay tax-free in the UK under Article 17 of the US-UK treaty: FEIE kills contribution room, FTC fixes it, Canada and France differ, §4975 breaks the Thiel play.
CRS: Automatic Exchange of Tax Information — How It Works
How the Common Reporting Standard works: which accounts and data are exchanged between countries, how CRS differs from FATCA, and what CRS 2.0 and CARF change from 2026.
Exit Tax: Tax on Departure When Changing Tax Residency (Germany, Canada, France)
What is exit tax: how Germany, Canada and France tax unrealized gains on shares when changing tax residency, who it affects and how deferral works.
Portugal IFICI (NHR 2.0): New Tax Regime Replacing Non-Habitual Resident
How IFICI works—the successor to NHR in Portugal: 20% on professional income, foreign income exemption, who qualifies, and how it differs from the old regime.
Cayman and Bahamas: Residence in Zero-Tax Jurisdictions
Residence by investment in the Cayman Islands and Bahamas: KYD and USD thresholds, zero income tax, and why a certificate from a zero-tax jurisdiction doesn't always sever prior residency.
Uruguay: Tax Residency and Tax Holidays (2026 Rules)
How to obtain Uruguay tax residency after the 2026 reform (Law 20.446): new investment threshold around 2 million USD, 11-year tax holidays, and 12% rate on foreign income.
Russian Currency Residency: Foreign Account Reporting and Annual Statements
Who remains a Russian currency resident, how to notify the tax authority about foreign accounts, what ODDS is, who is exempt after 183+ days abroad, and penalties under Article 15.25.
Loss of Russian Tax Residency: 183 Days and Consequences
When you cease to be a Russian tax resident, how it changes personal income tax (30% vs. 13–22%), what happens with real estate sales, and why remote work for a Russian employer is an exception.
The Five Flags Theory: A Map of Global Private-Wealth Diversification
Citizenship, tax residency, assets, business and where you live across jurisdictions: how the Five Flags Theory works today — adjusted for CRS, FATCA and Pillar Two.
Euroclear and Clearstream – Unfreezing assets
Blocked Russian securities at Euroclear and Clearstream: how the individual licence regimes of Belgium, Luxembourg and OFAC work, what the review actually turns on, and how long it takes.
Puerto Rico: Act 60 (0% on Capital Gains for New Residents)
Act 60 (Individual Resident Investor): 0% on capital gains, dividends, and interest for bona fide residents; 4% from 2027; 183-day test, $10k contribution. Tool for US persons.
Lock-up Period: Why Shares Cannot Be Sold Immediately After IPO
Lock-up period after IPO: what it is, standard 90–180 day terms, underwriter's right to early release, and why the restriction is doubly critical for SPV and secondary market investors.
Greece: non-dom €100k and benefits for pensioners and workers
Greek non-dom (Art. 5A): €100k/year on foreign income, 15 years, €500k investment; 7% for pensioners (5B); 50% relief for relocating workers (5C).
Thailand: Foreign Income Tax (2024) and LTR/DTV Visas
Thailand taxes remitted foreign income from 2024 (Por 161/162); proposed 2026 exemption; LTR visas (10 years, tax relief) and DTV visas (5 years) for remote workers.
Georgia: Territorial Tax, HNWI Status and 1% for Sole Proprietors
Georgia does not tax foreign-source income of individuals (territorial principle); residency via 183 days or HNWI status; 1% tax for sole proprietors; residence permits.
Italy: Flat Tax for New Residents (€300k from 2026)
Italy's neo-residenti regime (Art. 24-bis TUIR): fixed tax on foreign income €100k→€200k→€300k from 2026, 15 years, 9/10 year condition, investor and elective visa options.
Cyprus: Non-Dom and the 60-Day Rule
Cyprus non-dom status: 0% tax on dividends and interest for up to 17 years (SDC exemption), 60-day tax residency rule, GeSY contribution, residence permits and permanent residency.
Turkey: 20 Years Tax-Free on Foreign Income for New Residents
Turkey's new non-dom regime: 20 years tax-free on foreign income for new residents, 3-year non-residency requirement, 1% inheritance tax, and compliance risks.
Turkish Asset Amnesty 2026: How Varlık Barışı Works
Varlık Barışı 2026: which foreign and undeclared assets can be declared by July 31, 2027, rates 0-5%, deadlines and AML risks under Turkish law № 7582.
Turkey Residence Permit and Citizenship 2026: How to Become a Resident
Turkish residence permit (ikamet) types, property-based residence from USD 200,000, digital nomad visa, citizenship from USD 400,000, and how immigration status relates to tax residency.
CFC in the United Kingdom: TIOPA 2010 Part 9A, TOAA and the FIG Regime
British CFC rules: TIOPA 2010 Part 9A, gateway tests, charge calculation and interaction with Transfer of Assets Abroad and the FIG regime.
UAE Tax Residency: Cabinet Decision 85/2022, Golden Visa and 0% Personal Income Tax
UAE tax residency (Cabinet Decision 85/2022): 183/90-day tests, 0% personal income tax, Golden Visa, TRC, DMTT 15% for large groups from 2025.
EU ATAD I CFC: Articles 7-8 and Member State Implementation
CFC rules under EU ATAD I (Articles 7–8): two approaches to income attribution and implementation across EU Member States for holding structures.
Venture capital fund manager — VCFM
Venture Capital Fund Manager (VCFM) — a simplified MAS licensing regime in Singapore for VC fund managers. Eligibility, faster authorisation and fit for family offices.
VCC Singapore: Variable Capital Company for funds
Singapore's Variable Capital Company (2020) for investment funds: one legal entity holding multiple sub-funds with segregated assets — structure and use cases.
QSBS §1202 for the American founder: why timing decides everything
How IRC §1202 excludes up to 100% of QSBS gain, what OBBBA 2025 changed (50/75/100% tiers, $15M cap), stacking through non-grantor trusts, §1045 and why timing decides for Americans abroad.
How to invest in unicorn shares on the secondary market
How to buy pre-IPO unicorn shares on the secondary market: deals between existing shareholders. Access, structures and minimums for private-capital investors.
OFAC sanctions removal: asset unblocking procedure
Removing OFAC sanctions and unblocking assets: how the U.S. Treasury process works, delisting petitions and what UHNW clients must document to release frozen funds.
OECD Pillar 2 in Hong Kong: 15% Global Minimum Tax for Large Multinational Groups
From January 1, 2025, Hong Kong applies OECD Pillar 2 at 15% for MNE groups above EUR750M revenue. Impact on private holdings.
Side letter: individual LP terms in a fund
Side letters in private funds: bilateral agreements granting an LP terms beyond the standard subscription docs. What they cover, MFN clauses and how LPs negotiate them.
Strategy: Beckham Law + Hong Kong
Tax planning strategy combining Spanish Beckham Law residency with a Hong Kong company: offshore income, PE risks, dividends, expenses, and compliance controls.
Modelo 720: Spain's Foreign Asset Declaration
Spain's Modelo 720: the €50,000 threshold per asset block, the 1 January–31 March window, LGT arts 198–199 penalties after C-788/19, and Modelo 721 for crypto.
US Tax Controls for Family Offices
A practical operating model for U.S. persons, families and founders managing worldwide tax reporting, FATCA, FBAR, CFC, PFIC, trusts and advisor workflow.
Remittance basis after 6 April 2025
Legal guide to the abolition of the UK remittance basis, pre-6 April 2025 pools, TRF, mixed funds and transitional rules.
Planning before UK residence
Legal guide to pre-arrival UK tax planning for FIG, OWR, foreign companies, offshore funds, trusts, IHT and residence evidence.
Offshore Funds and UK Tax
Legal guide to UK reporting fund status, non-reporting funds, offshore income gains, foreign ETFs and investment portfolios.
Overseas Workday Relief
Legal guide to UK Overseas Workday Relief after 6 April 2025, foreign workdays, employment income, RSUs, bonuses and evidence.
Leaving the UK: Tax on Departure
Legal guide to leaving UK tax residence, P85, SA109, split year, temporary non-residence, UK property and IHT tail risk.
HMRC enquiries and cleanup
Legal guide to HMRC offshore enquiries, CRS data, Worldwide Disclosure Facility, penalties, amended returns and evidence repair.
Foreign tax credit and treaties
Legal guide to UK foreign tax credit relief, double tax treaties, treaty residence, withholding tax and Self Assessment reporting.
UK Family Office Records and Tax Evidence
Legal guide to UK residence files, ownership maps, source-of-funds records, CRS self-certifications and evidence architecture.
CRS, FATCA and HMRC data
Legal guide to CRS, FATCA-style reporting, HMRC offshore data, Self Assessment consistency and family office evidence.
UK tax residence
Legal guide to the UK Statutory Residence Test, day counting, ties, split years, temporary non-residence and treaty residence.
UK Tax on Worldwide Income and Gains
Legal guide to UK taxation of foreign income, gains, cryptoassets, Self Assessment, SA106, SA108 and SA109.
US Tax Enforcement and Offshore Cleanup
How U.S. persons approach FATCA data, FBAR, Form 8938, late international forms, streamlined procedures, voluntary disclosure, passport risk and cleanup strategy.
U.S. tax planning tools
Legal U.S. tax planning tools for Americans abroad: FEIE, foreign tax credit, totalization, entity classification, CFC/PFIC review, trusts, pre-immigration and expatriation planning.
US Expatriation and Exit Tax
A practical guide to U.S. expatriation, long-term green card termination, covered expatriate status, Form 8854, exit tax and five-year compliance certification.
FEIE and foreign tax credit
How U.S. persons abroad choose between foreign earned income exclusion and foreign tax credit: Form 2555, Form 1116, housing exclusion and double-tax rules.
Foreign trusts and Form 3520
How U.S. persons approach foreign trusts, gifts, inheritance, Form 3520, Form 3520-A, grantor trust status and estate planning controls.
US Foreign Entity Forms: 8865, 8858 and 926
A practical map for U.S. persons reporting foreign partnerships, disregarded entities, branches and transfers to foreign corporations on Forms 8865, 8858 and 926.
PFIC and Form 8621
Why foreign mutual funds, ETFs and passive holding companies can create PFIC issues for U.S. persons: Form 8621, QEF, mark-to-market and excess distributions.
FATCA, FBAR and Form 8938
How FATCA, FBAR and Form 8938 work for U.S. persons abroad: foreign bank reporting, FinCEN Form 114, specified foreign financial assets and penalties.
US CFC Rules: Form 5471, Subpart F and GILTI
How U.S. persons report controlled foreign corporations, Subpart F income, GILTI, Form 5471, Form 8992, check-the-box planning and entity reporting.
UK FIG Regime: Foreign Income and Gains
The UK Foreign Income and Gains (FIG) regime from 6 April 2025: relief from UK tax on foreign income and gains for the first 4 years of residence; 10-year non-residence condition; replaced remittance.
UK Non-Dom Reform 2025: FIG Regime, TRF and Your Options
The remittance basis ended on 6 April 2025. How the new FIG regime and Temporary Repatriation Facility change planning for internationally mobile private capital.