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, ownership structure and timing of income recognition. The section separates general models, country rules and practical private-capital scenarios.
The section does not reduce a decision to expected return. A useful comparison also covers legal wrapper, liquidity, currency, tax timing, reporting, control and transferability. Keep the instrument, the jurisdiction and the owner-specific scenario separate: the same investment can produce a different outcome under another residence, ownership route or funding source. Collect those factors first, then move to calculations and professional verification.
Use the topic as a reading route. Open an overview hub, then two or three closely relevant articles and compare them against one consistent set of criteria. On every page, check the modification date, scope and links to primary sources because rules, pricing and administrative practice change. If the research supports a decision about a specific person, company or asset, turn the shortlisted options into questions and confirm the current conditions before acting.
The catalogue is generated from the current Published corpus. A page appears here only when its public snapshot matches the active index revision; archived and quarantined material is excluded. This is a research map, not individual legal, tax or investment advice.
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.
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.
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 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.
Private Investor Infrastructure: A Map of Platforms for Family Offices
A map of private investor infrastructure: access to private equity (Moonfare, iCapital), secondary pre-IPO markets (Hiive, Forge, NPM), SPV and cap table (Carta, AngelList, Sydecar), crypto custody, and alternative.
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.
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.
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.
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.
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.
Art and Collectibles as an Asset Class
Art cluster hub: the economics of collectible assets, title and provenance, freeports, the AML regime, ownership structures and succession — with routes to the 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.
Articles
UAE Holding Company for an EU Operating Business: Anti-Abuse, Beneficial Ownership, Substance
UAE holding company over an EU operating business: 0%/9% UAE corporate tax, participation exemption (Art. 23 FDL 47/2022), no Parent-Subsidiary shelter, ATAD GAAR and beneficial-ownership tests, and the substance that suffices.
Singapore IP Company, UK-Resident Owner: The IDI Box Meets UK CFC Rules
Holding IP in a Singapore company under the IP Development Incentive (5%/10%, ITA s.43X, nexus approach) while the family lives in the UK: UK CFC rules (TIOPA 2010 Part 9A), central management and control, and the substance both sides read.
Singapore Holding Company with Founders in Europe: Where Does Management Live?
Singapore holding company with founders living in Europe: where the operating company goes, why effective management decides residence (ITA s.2), and how ATAD-based EU CFC rules (Directive 2016/1164) treat the holding.
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.
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.
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 20.08.2026.
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.
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.
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.
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.
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.
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 residence arises. The reader assembles the pair: the exit column of country A plus the entry column of country B.
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.
Hong Kong's Tax Treaty Network
Hong Kong's CDTA network as at August 2026: 51 treaties in force, 8 signed and pending, 17 in negotiation. Withholding rates for the Mainland, Luxembourg, the Netherlands, the UAE and the UK; how the IRD issues a Certificate of Resident Status in 21 working days and when the substance Appendix bites; Hong Kong's MLI reservations; the missing US and Singapore treaties; CARF, CRS and Pillar Two.
Jersey Trust, Italian Family: Where Does the Holding Company Go?
Jersey trust with an Italian-resident family: where to place the holding company, how Italian CFC rules (art. 167 TUIR) and trust interposition read the stack, and why effective management must stay out of Italy.
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.
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.
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.
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.
Sentenor Bank: Public Status, Licence and Service Availability
Sentenor Bank Corporation in Dominica: claimed FSU licence, current account availability, onboarding, published services and undisclosed client-money protections.
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).
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.
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.
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.
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.
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 (ECLI:ES:AN:2026:1851), BFH case law on § 8 AO, and the residence certificate procedure in Spain, Germany, the UAE and Andorra.
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.
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.
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.
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.
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
A comparison of the rules for info-products and creators: ad disclosure (FTC, CAP Code, DSA, erid), registers in Russia, Spain, Italy and the UAE, ceilings from 6% and 10% of turnover to criminal cases in Russia.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 the reliefs combine and where the limits are.
Charitable Deduction: Appreciated Stock, CRT/CLT and DAFs
The mechanics of 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 and how to run the numbers.