Certificate of Resident Status for a Hong Kong Company: How It Works in Practice
How a Hong Kong company run from abroad obtains a Certificate of Resident Status for Russia or Belarus: the form, timing, apostille and the offshore claim.
Tax regimes
EU investment firm: Cyprus, Malta, Bulgaria or Lithuania
Cyprus, Malta, Bulgaria or Lithuania for a MiFID II firm: capital is the same, so fees, the clock, investor compensation, CFD rules, staff costs and tax decide.
Relocating with a Trust: What Twelve Destination Countries Do on Arrival
What happens to a trust when its settlor or beneficiaries move to the UK, Italy, Spain, France, Germany, Switzerland, Portugal, Cyprus, UAE, US, Canada, Israel.
Operating Company for a Non-Resident Owner: US LLC, UK, Estonia, Ireland, Cyprus, UAE, Hong Kong, Singapore and Georgia
Nine vehicles for a non-resident owner compared: company tax, residence test, local director, payout tax, audit, fees, Stripe and bank access, worked example.
Residence Total Cost Matrix: Five Years of Status in Twelve Jurisdictions
Five-year cost of residence in 12 jurisdictions for one family: state charges, locked capital, housing rules, tax on €300k passive income, PR horizon.
Insurance Wrapper Jurisdictions: Where to Issue a Unit-Linked or PPLI Policy
Luxembourg, Ireland, Liechtenstein, Bermuda, Cayman, Singapore, Hong Kong, Isle of Man and Guernsey compared, and how FR, IT, ES, DE, UK and US tax the policy.
Company in Bulgaria (EOOD/OOD): 10% Tax, 5% Dividends and Substance
Bulgarian EOOD and OOD: 10% corporate tax, 5% dividend tax (0% to EU/EEA companies, except hidden profit distribution), €51,130 VAT threshold, euro since 2026.
EMI in Lithuania or Bulgaria: A Comparison
Lithuania or Bulgaria for an EMI licence: the same €350,000 and the same three-month statutory clock, so the choice turns on the regulator's fee and sub-clock, CENTROlink against ZPUPS Art. 130a, register depth and Bulgaria's FATF listing.
Redomiciliation Routes: Moving a Company or a Fund to Another Register
Nineteen continuation regimes compared: which registers admit a company and let it leave, exit tax, substance, licences, fees, funds and the alternatives.
Cyprus Tax Reform from 2026: Company, Individual, Crypto-Assets
The Cyprus reform in force from 1 January 2026: 15% corporate tax, a personal scale with a EUR 22,000 nil band, SDC of 5% on dividends and 17% on interest, 8% on crypto-assets, and the transition for pre-2026 profits.
TRF Designation Mechanics
TRF designation after Finance Act 2026: rates by designation year, eligibility, the double designation requirement, mixed funds and correcting errors.
Section 2801: Gifts and Bequests from Covered Expatriates
Who pays the section 2801 tax: a U.S. recipient determined by domicile, 40% above the annual exclusion, TD 10027 effective January 14, 2025, Form 708 for 2025 due June 15, 2027, the section 2801 ratio and the electing foreign trust.
The EU Tax Omnibus and the DAC Recast: The 24 June 2026 Proposals
Two Commission proposals of 24 June 2026: a narrow carve-out for Pillar Two groups, Category A hallmarks deleted, 90 days instead of 30, imported hybrid mismatches removed, a single 30% of EBITDA and a mandatory EUR 3 million. Status: proposals; the omnibus and the DAC recast have different application dates.
GloBE Information Return: Global Minimum Tax Reporting
Who files the GIR and where, the 15- and 18-month deadlines, the common understanding on central filing, exchange under the GIR MCAA and DAC9, and penalties.
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.
Transfer Pricing: Arm's Length Principle, Methods and Disputes
How the arm's length principle prices controlled transactions between associated enterprises — delineation, the five OECD methods, loans, IP/DEMPE, services, and the APA/MAP route when two states disagree.
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.
Singapore Advance Rulings and Approvals: IRAS, MAS and EDB
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.
Companies and Holdings: Jurisdiction, Form and Place of Management
Map of the corporate domain: legal form and company residence, substance and anti-abuse tests, holding jurisdictions compared, and the sanctions filter that comes first.
Migration: Residence Permits, Citizenship and Tax Residence
A map of the migration domain: three independent variables, the eight-step route model, seven entry types on shared axes, and a detailed guide to each branch.
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.
United Kingdom: Tax, Banking and Structures for Private Capital
The UK after non-dom abolition: 4-year FIG regime, TRF, residence-based IHT after 10 of 20 years, SRT, banks from Coutts to fintechs, visa routes.
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.
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 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.
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.
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 Trusts with Italian Families: Holding Location and CFC Rules
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.
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.
Hong Kong's Tax Treaty Network
Hong Kong's CDTA network as at September 2026: 51 in force, 9 signed, 17 in negotiation. Withholding rates, Certificate of Resident Status in 21 working days, MLI reservations, CARF and Pillar Two.
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 tested UK route, Article 17 against Articles 7 and 15.
Selling the Business: Preparation, Deal Structure and Exit Tax
Share deal or asset deal, SSE and §8b KStG, Sperrfrist and 150-0 B ter, BADR at 18% from 6 April 2026, earn-outs, W&I and what happens to the team's options.
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.
Earned Settlement: British ILR in Three, Five or Ten Years
The UK earned settlement reform: a 10-year baseline, reductions at £50,270 and £125,140, talent routes, and the rules that actually apply in August 2026.
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.
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.
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.
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.
Relocating on Platform Income: Visa and Tax Routes for Creators
Spain's DNV will not take pure AdSense: a three-month client contract is required. Portugal D8 asks €3,680 a month, Thailand DTV 500,000 THB, Georgia 1%.
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.
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 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.
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.
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.
Saudi Arabia: Premium Residency, Zero Income Tax and Athletes' Money
No income tax on salary, 15% VAT, Premium Residency at SAR 800,000 or 100,000 a year, RHQ at 0% for 30 years, and the temporary non-residence trap at home.
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.
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.
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.
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).
Creator Holdco: Turning Reach into Capital
§ 1221(a)(3) IRC turns the sale of a channel into ordinary income: why a creator needs a holdco, a C-corp and QSBS with a $15m cap, and how the Beast round works.
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.
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.
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.
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.
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.
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.
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.
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.
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.
Yacht Ownership: Flag, VAT, Charter and Crew
Flag map from the Red Ensign Group to Malta, charter rules country by country, VAT and temporary admission, crew and MLC, radio and MMSI, 2025–2026 trends and Q/A.
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.
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.
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.
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.
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.
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 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.
Singapore Personal Income Tax: Rates, Reliefs and Non-Resident Rules
Singapore income tax rates for YA2026: resident brackets 0–24%, marginal vs effective rate, 183-day residency, non-residents 15% or 24%, reliefs, IR21.
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.
Singapore Capital Gains Tax vs Trading Income: IRAS Badges of Trade
Singapore has no capital gains tax, but IRAS taxes trading gains: the badges of trade, s.13W safe harbour (20%/24 months), s.10L foreign gains and SSD.
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.
Hong Kong FIHV vs Singapore 13O: The Two SFO Regimes Compared
Hong Kong FIHV against Singapore 13O and 13U: HK$240m vs S$20m thresholds, substance costs, Bill 2026 status and the CIES vs GIP migration bonus compared.
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.
Kazakhstan: Banks, Residence, Business and the AIFC
Kazakhstan hub for 2026: the new Tax Code, 5% dividends, banks for non-residents, residence permits, AIFC benefits to 2066 and legal crypto.
AIFC: Common Law and Tax Benefits Until 2066 in Astana
The AIFC regime: 0% CIT and VAT on financial services until 2066, an English-law court, AFSA licence fees from $7,000, substance rules. August 2026.
Designated Investments and Specified Income: The Scope of Singapore's Fund Tax Exemptions
What counts as designated investments under Singapore's 13D/13O/13U fund tax exemptions: Fifth Schedule scope, exclusions, crypto, SG property. July 2026.
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.
Section 13O for a Singapore Single Family Office: 2026 Conditions
Section 13O for Singapore single family offices in 2026: S$20m in designated investments, two investment professionals, S$200K–1m spending, CDR, MAS award.
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.
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.
Company in Kazakhstan for Non-Residents: LLP, Sole Trader and 2026 Taxes
Setting up an LLP in Kazakhstan as a non-resident in 2026: C5 visa, one-day eGov registration, 4% simplified regime, 20% CIT, 16% VAT, 15% dividend WHT.
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 its 2025 decree rewrite, Bienes Personales → 0.25%, REIBP and Milei's reforms.
China: Company, Banks, Payments, and Residency
China for business: WFOE and regions, a bank map for foreign trade, CIPS payments and SAFE currency control, work-based residency, taxes, and the sanctions layer.
Cayman Islands Company: Exempted Company, Zero Tax and Substance
How a Cayman exempted company works: zero tax and tax undertaking, economic substance, beneficial ownership register, reputation and banking, when the Caymans are appropriate.
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.
UAE: Residency, Taxes, Companies and Banks
UAE map: golden visa and tax residency, mainland vs free zone vs ADGM/DIFC, banks for companies and individuals, Russia tax treaty from 2026.
Spain: visas, Beckham Law and taxes
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.
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 19% at the top band, 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.
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.
Hong Kong FIHV: Tax Concessions for Family-Owned Investment Vehicles
0% Hong Kong profits tax for a family-owned investment holding vehicle run by a single-family office: conditions, the HK$240m threshold, the 2026 Bill, and CFC/PFIC risk for US persons.
Tax Transparency: CRS, FATCA and Financial Information Exchange
Tax transparency hub: exchange on request, FATCA, CRS, CARF, DAC6–DAC9, CbCR and UBO registers — what each channel shows about a private client and their structure, and where the system is heading.
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.
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.
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.
Holding Structures: Netherlands, Luxembourg, Cyprus, Singapore, UAE
Holding structures end to end: the investor→holdco→opco path, eight independent tax tests (residence, PE, beneficial ownership, PPT, CFC, TP, substance), NL vs Cyprus flow economics, Pillar Two.
Tax Residency: 183-Day Rule, Centre of Vital Interests and Tax Treaties
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.
U.S. Tax Residency and U.S. Person Status
Who is a U.S. person for tax purposes under IRC §7701(a)(30): citizens, green card holders, substantial presence residents, U.S. entities, estates, trusts.
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.
Controlled Foreign Companies: Income, Control and Tax Residence
CFC rules in Russia, the United States, the United Kingdom and the EU: control, attribution of foreign income, exemptions and tax residence.
Singapore — Business, Investments, Residence, Banking
Singapore as a hub for private capital: company formation, tax residence, funds, and banking under territorial taxation. Where to start and how to structure.
Hong Kong: Companies, Residency, Banking and Licences
Hong Kong as a hub: company registration, residency, banking and licenses. English common law and territorial tax principle for private capital structures.
Setting Up a Private Fund in Singapore: VCFM, Section 13D/13O/13U and VCC Combined
Setting up a private fund in Singapore: combining VCC, VCFM manager and Section 13D/13O/13U tax regimes—why registration alone is not enough.
Carried interest 2026: the jurisdiction map for fund principals
Carried interest in 2026: the UK moves it into trading profits (34.075%/47%) and reaches non-residents, Luxembourg offers 11.45% or exemption, Italy 26%, France 31.4% PFU, the US keeps § 1061.
Ireland Section 110 SPVs and ICAVs: Taxation and US Investors
How an Irish Section 110 SPV zeroes its tax base through profit-participating notes, why the ICAV can check-the-box and kill PFIC, and where ATAD and anti-hybrid bite.
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.
Monaco company
Setting up a company in Monaco, a sovereign microstate for international business structuring and wealth protection. Tax framework and fit for UHNWIs.
Special Administrative Regions (SAR): Redomiciliation of Holdings to Russia
How special administrative regions on Russky and Oktyabrsky islands work, international holding company (IHC) status, and redomiciliation of holdings from abroad.
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.
Seychelles IBC: Territorial Tax, Substance and Banking
Seychelles International Business Company under IBC Act 2016: territorial tax after 2019 reform, economic substance requirements, banking limitations and EU list status.
Panama Private Foundation (Law 25): Structure, Taxes, Succession
Panama Fundación de Interés Privado under Law 25 of 1995: founder, council, protector, beneficiaries in private regulations, $10,000 contribution, territorial tax, FATF and EU status.
Holding Company in Switzerland: Rates, Participation Relief, Pillar Two
Swiss holding company: cantonal rates 12–15%, participation relief, TRAF 2020 reform, global minimum tax Pillar Two (QDMTT/IIR), and substance requirements.
Liechtenstein Foundation (Stiftung): Family Foundation and 12.5% Tax
Liechtenstein Stiftung under PGR (Art. 552): family foundation without members, privacy through deposit, beneficiary types, 12.5% tax and PVS status, Pillar Two impact.
GAAR and Principal Purpose Test: Tax Anti-Abuse Rules
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.
Crypto Taxation by Country
Four patterns of crypto taxation across 16 jurisdictions: zero capital gains, holding-period exemption, a dedicated low rate, full taxation. Wealth tax, exit tax, CARF waves.
Luxembourg Funds: UCITS, SIF and RAIF
Funds in Luxembourg: retail UCITS and alternative SIF/RAIF — structures, subscription tax (taxe d'abonnement), AIFM and the EU passport, CSSF supervision.
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.
Holding Ladder and Dividend Flows
How dividends climb the holding ladder: withholding tax, Parent-Subsidiary and Interest & Royalties Directives, beneficial ownership, PPT, and CJEU Danish cases.
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.
Malta Holding: 6/7 Refund System and Effective 5% Rate
How Malta's full imputation system and 6/7 tax refund work, participation exemption for holdings, substance requirements, and the impact of Pillar Two.
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.
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.
South Dakota Dynasty Trust: Taxation of US Citizens Living in the UK
South Dakota dynasty trust for an American who becomes UK-resident: how Settlements Code, ToAA and s.86/s.87 TCGA collapse deferral, and residence-based IHT from 6 April 2025 reaches trust assets.
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 and the Carte de Séjour
Monaco carte de séjour: who needs one, card types and fees, bank attestation; 0% income tax, the 1963 French exception, inheritance tax on Monaco assets.
Renunciation of Citizenship and the Risk of Statelessness
How citizenship renunciation works, why becoming stateless is prohibited, what a covered expatriate is, and the US exit tax when renouncing a US passport.
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.
Relocation from Russia: Armenia, Kazakhstan, Georgia, UAE
Comparison of relocation destinations from Russia: taxes and residence permits in Armenia, Kazakhstan, Georgia, and UAE, DTAA status after Decree No. 585, and the new Russia–UAE agreement from 2026.
Holding in Ireland: 12.5%, participation exemption and Pillar Two
Ireland as a holding jurisdiction: 12.5% on trading profits, participation exemption for foreign dividends from 2025 and for capital gains, 75 tax treaties in force and Pillar Two rules.
Mauritius Residence: 15%, Remittance Regime and Visa Routes
Mauritius taxes and residence: 15% rate and Fair Share Contribution, foreign income taxed on remittance, Occupation Permit, Premium Visa and property residence routes.
Estonian Company (OÜ) and e-Residency: 0% on Retained Earnings and 22/78 on Distribution
Estonian e-Residency: digital ID, card pickup, OÜ registration within a working day for €265, what it does not give; 0% on retained profit, 22/78 payout.
New Zealand Foreign Trusts: Foreign Income Taxation and IRD Registration
How a New Zealand foreign trust works: resident trustee, foreign exemption trust, IRD registration, annual return, financial statements, CRS/FATCA and tax red flags.
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.
Trusts and CFC Rules: When a Foreign Trust Is a Controlled Foreign Company
When a foreign trust or foundation becomes a CFC for a Russian tax resident: controlling person, notifications, undistributed profits, PIT and distributions.
Inheritance Tax: Country-by-Country Map
Inheritance tax map for 2026: US and UK estate tax at 40%, French, German, Spanish and Italian rates, zero-tax regimes and situs traps for non-residents.
Gift Tax and Lifetime Gifting
Lifetime transfer of assets as an estate planning tool: gift tax, the UK 7-year rule, clawback into forced heirship calculations, and where gifting beats inheritance.
US Estate Tax: The US-Situs Trap for Non-Residents
Non-residents face only a $60,000 estate tax exemption on US-situs assets (US stocks, real estate), with rates up to 40%. How the trap works and treaty relief.
Trusts and Inheritance Tax: UK IHT After the 2025 Reform
How UK inheritance tax (40%) affects trusts and non-residents after the 6 April 2025 reform: transition to residence-based regime, long-term resident 10 of 20 years.
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.
UAE: Fund Management in ADGM and DIFC Under Own and Third-Party Licenses
How to launch fund management in UAE's ADGM and DIFC: own Category 3C license, regulatory hosting platforms, representative offices, and external fund manager regimes.
Gibraltar company
Registering a Gibraltar company for international structuring: English common law, GFSC oversight and substance. How UHNW owners use it cross-border.
Croatia: Digital Nomad Permit
Full 2026 guide to Croatia's digital nomad permit: €3,622.50/month threshold, up to 18 months, foreign employment income exempt from Croatian tax, process, documents, typical mistakes.
Italy Digital Nomad Visa: For Highly Skilled Remote Workers
Italy's nomad visa in 2026: €25–28k income band by consulate, art. 27-quater qualification, no nulla osta, the 8-day Questura window, and taxes — forfettario, impatriati, €300k flat tax.
Portugal D8: Digital Nomad Visa (Residence and Temporary Stay)
Full 2026 D8 guide: €3,680/month income, €11,040 savings, temporary stay vs residence, AIMA delays and ação de intimação, IFICI, social security, and the new 10-year citizenship clock.
Exit Tax: Tax on Departure When Changing Tax Residency
Exit tax across eleven jurisdictions: trigger, residence test, threshold, rate, deferral and the tail after departure in Germany, France, Spain, the US and more.
Cyprus Holding: 15% Corporate Tax from 2026, IP Box and Non-Dom Link
The Cyprus holding company in 2026: the Cap. 113 form, director and secretary, beneficial owner register, audit, the 15% rate, dividend exemption, 0% withholding and the non-dom link.
Luxembourg SOPARFI: Classic Holding with Participation Exemption
How a Luxembourg SOPARFI holding works: dividend and capital gains exemption under Art. 166, combined rate of 23.87% from 2025, and requirements for stake and substance.
Netherlands Holding Company (BV): Participation Exemption and Tax Treaty Network
Why Dutch BV remains a classic holding structure: dividend and capital gains exemption via participation exemption, corporate tax rates, and extensive tax treaty network.
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.
US LLC (Wyoming and Delaware) for Non-Residents: Disregarded Entity, ECI and Form 5472
When a US LLC pays no federal tax, what ECI and ETBUS mean, why Form 5472 is required with a $25,000 penalty, and how Wyoming differs from Delaware for non-residents.
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.
Paraguay: Residence After the 2022 Reform and Territorial Tax
How to obtain Paraguay residence after Law 6984/2022: temporary residence without deposit, investor route from 70,000 USD, and territorial tax with 0% on foreign income.
Malaysia MM2H: "Second Home" Program, Tiers and Taxes
Malaysia MM2H: deposits, property, programme terms and stay requirements for Silver, Gold, Platinum and Forest City, with separate tax-residence rules.
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.
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.
UK Overseas Workday Relief (OWR): Tax Relief for New Residents
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.
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.
UK Tax Information Exchange: CRS, FATCA and HMRC Data
CRS and FATCA in the UK: ITC Regulations 2015, UK FI registration and 31 May reporting, 2025 penalties, CRS 2.0 and CARF, HMRC nudge letters, WDF, time limits and the end of non-dom status.
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.
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.
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.
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
FATCA as a system: 30% withholding, FFI Agreement, Model 1 and 2 IGAs, GIIN. FBAR and Form 8938 for US persons: thresholds, deadlines, penalties, Bittner, streamlined.
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.
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).
Beckham Law: Spain's special tax regime, Modelo 149 and Modelo 151
Spain's Beckham Law: 24% on worldwide salary, 0% on foreign passive income for 6 years; Modelo 149 election, Modelo 151 annual return, no Modelo 720.
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.
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.
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.
Portugal Golden Visa: Investment Funds, Residence and Citizenship
Portugal Golden Visa (ARI): residency through €500k fund investment, IFICI tax regime and path to citizenship (10 years from 19 May 2026, 7 for EU/CPLP). Conditions for private capital.
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.
Section 13O and Section 13U: Singapore Fund Tax Exemption Schemes
Singapore's 13O, 13OA and 13U schemes exempt fund income from 17% tax: AUM, spending and investment-professional tests, MAS award and FDD Cir 05/2026.
Section 13D: Singapore Tax Regime for Offshore Funds
Section 13D Income Tax Act 1947 — Singapore exemption for offshore funds managed by a local fund manager: conditions, restrictions, and differences from 13O/13U.
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.
Gibraltar Category 2 and HEPSS: tax certificates, residence and substance
Gibraltar Category 2 and HEPSS tax certificates explained: residence, substance and capped tax for HNW — and why this is not a residence-by-investment programme.
Malta GRP: special tax status, residence card and remittance basis
Malta's Global Residence Programme: special tax status, residence card and the remittance basis of taxation. Who qualifies and fit for UHNW relocation.
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.
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.
Spanish Beckham Regime and a Hong Kong Company: Income and CFC Rules
Tax planning strategy combining Spanish Beckham Law residency with a Hong Kong company: offshore income, PE risks, dividends, expenses, and compliance controls.
Company in China
Guide to forming a WFOE in mainland China: foreign ownership, tax, fapiao, SAFE currency control, bank account setup, and regional choice.