A map of the family perimeter: the matrimonial regime first, then the instrument, then the event. Regulations 2016/1103 and 650/2012, waiver of the reserved share, governance and the family office.
Jurisdiction under Regulation (EU) 2019/1111, the race of fora and lis pendens, English rules under s. 5(2) DMPA 1973, recognition of foreign divorces, and why money does not follow the divorce.
Three trust jurisdictions compared from primary sources: firewall, reserved powers, perpetuity, taxation, disclosure and CRS/CARF timing, trustee licensing and published JFSC, MAS and IRD tariffs.
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.
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.
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.
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.
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.
How family charitable capital is structured: private, operating and conduit foundations, DAFs, supporting organisations and CRTs, Gift Aid, the 10% IHT threshold and cross-border giving.
Community of acquests, separation of property and deferred community: default regimes in France, Germany, England, the US and Russia, plus EU Reg 2016/1103.
The legal mechanics of owning art: title and provenance, UNESCO and UNIDROIT, Nazi-era restitution, art-secured lending, export control and AML.
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.
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.
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.
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.
How estates are divided without a will in England and Wales: £322,000 statutory legacy for spouse, freedom of testation, the 1975 Act, 40% inheritance tax and residence-based regime from April 2025.
Forced share in Spain: two-thirds to children under common law, usufruct to spouse, symbolic legítima in Catalonia and Navarre, choice of law under Brussels IV and regional inheritance tax ISD.
Forced heirship (legittima) in Italy for spouses and children, patto di famiglia for business transfer, foreign trust recognition under Hague Convention, 4–8% inheritance tax.
Mandatory share for children in France (half, two-thirds, three-quarters), surviving spouse rights, Brussels IV choice of law, droit de prélèvement 2021, assurance-vie.
Two classes of heirs under China's 2021 Civil Code, spousal share, testamentary reform, "necessary portion" (Art. 1141), testamentary trusts, and no inheritance tax.
Inheritance without a will in the USA: probate and state formulas, no forced share for children, spousal elective share, federal estate tax ($15M / 40%) and the $60K trap for non-residents.
What happens to UAE assets on death: frozen accounts, Sharia and Decree-Law 41/2022 defaults, DIFC Wills (AED 10,000) vs ADJD (AED 950), probate and guardianship of minors.
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.
Liechtenstein Stiftung under PGR (Art. 552): family foundation without members, privacy through deposit, beneficiary types, 12.5% tax and PVS status, Pillar Two impact.
Channel Islands trusts: Trusts (Jersey) Law 1984 and Guernsey 2007, settlor's reserved powers, firewall protection from forced heirship and creditors, tax neutrality.
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.
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.
How Monaco's tax regime works: zero personal income tax, French citizens exception under the 1963 convention, inheritance tax, and residency requirements.
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.
What happens to inheritance of minor children: guardianship, property management until adulthood, appointing a guardian in a will, and the role of trusts for children.
What happens to assets and decisions if the owner is alive but incapacitated: power of attorney, living will, and medical directives. A plan must cover this scenario.
Why foreign real estate is inherited under the law of the country where it is located (lex rei sitae), how this creates forced heirship and double taxation issues.
How foreign bank accounts and brokerage portfolios are inherited: account freezing, bank requirements for heirs, US-situs for American stocks, and the role of designated beneficiaries.
What is a family charter: a set of rules for ownership, management, and succession of family capital. Why it's needed, what it includes, and how it relates to legal documents.
How to transfer a family business to the next generation without collapse: separating ownership and management, shareholder agreements, foundation or holding at the top.
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.
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.
Discretionary, fixed, revocable and irrevocable, life interest and purpose trusts—how trust types differ and which to choose for inheritance, asset protection and charity.
Why consolidate family assets into a holding company before inheritance: single control point, shares instead of scattered assets, and linking the holding with a foundation or trust.
A trust basics map: settlor, trustee, beneficiaries, protector, legal and beneficial ownership, fiduciary duties, reserved powers and sham risk.
How civil law countries recognize common law trusts: the 1985 Hague Convention on the Law Applicable to Trusts, and why foundations are sometimes more convenient than trusts.
Who inherits and in what order without a will in Russia: eight lines of succession, spousal share, representation rights, and dependent heirs.
New Russian inheritance law tools since 2019: inheritance contract and joint will of spouses—how they work and differ from a standard will.
Three connecting factors that determine succession: domicile (common law), habitual residence (EU) and citizenship. How they differ and affect applicable law and taxes.
A single document proving heir, executor or administrator status across the EU: the European Certificate of Succession under Regulation 650/2012 — why it matters and how it works.
Unit-linked policies from Luxembourg and Ireland as a capital wrapper: liquidity for inheritance tax, tax deferral, direct transfer to beneficiaries, and asset protection.
How to pass on bitcoin, tokens and accounts: the private key problem, access without revealing seed phrases, legal status of crypto in estates, and the role of foundations or trusts.
Why separate wills are needed for different countries, how to avoid mutual revocation, and why probate can drag on for years. Mirror wills, formalities, and forced heirship.
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.
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.
Which law governs cross-border inheritance: domicile and habitual residence, lex rei sitae for real estate, and choice of nationality law under EU Regulation 650/2012.
Who inherits despite a will: statutory share in Russia (Art. 1149 Civil Code), réserve in France, legítima in Spain, Sharia in UAE—and testamentary freedom in common law.
Personal foundation (since 2022) and hereditary foundation under Art. 123.20-8 of the Civil Code: 15% profit tax benefit, beneficiary income tax, ₽100M threshold, business succession.
How SFO differs from MFO, which jurisdictions family offices choose (Singapore 13O/13U and VCC, UAE, Switzerland), why family charter matters and succession planning.
Cross-border succession planning: situs wills, trusts and foundations, choice of law under Regulation 650/2012, forced heirship, probate and estate taxes.
What is a private foundation, how it differs from a trust, and how Liechtenstein Stiftung, Panama Private Interest Foundation, and Jersey Foundations work.