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.
Tax treatment of art collections: US FMV charitable deductions, UK Acceptance in Lieu and Cultural Gifts Scheme, French dation en paiement, freeport customs suspension, fractional gifts, insurance proceeds and valuation requirements.
The legal mechanics of owning art: title and provenance, UNESCO and UNIDROIT, Nazi-era restitution, art-secured lending, export control and AML.
LP-led and GP-led fund secondaries: continuation fund mechanics, status quo option, fairness opinions, conflicts of interest, and 2025-2026 market data.
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.
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.
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.
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.
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.
What belongs in a family IPS, how an investment committee governs policy, what the prudent investor rule demands, and why rebalancing beats manager selection.
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.
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.
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 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.
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.
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.
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.
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.
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.
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 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.
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.
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.
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.
Serbia taxes 2026: 10% salary tax, 35% contributions, 15% dividends and capital gains, annual surtax 10-15%, pausal regime, 50% crypto relief, Russia treaty.
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.
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.
London, Italy, France, Portugal, Spain, Singapore, Bulgaria, Austria, the UAE, Greece, Cyprus: what non-residents need for a transaction, entry tax from 2% to 60%, whether purchase grants residency, and how to structure ownership.
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.
How securities custody works: the custody chain, CSD and ICSD depositories (Euroclear, Clearstream), global custodians and Pershing, asset segregation and sanctions risk.
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.
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.
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.
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.
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.
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.
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 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.
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.
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.
How carried interest taxation changed 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 the 31.4% PFU, and the US keeps § 1061 intact.
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 in the English tradition: reserved activities, legal professional privilege, client account, undertakings, trust practice, and recognition of status outside England.
Access regimes to private markets: accredited investor in the US, professional client in the EU, qualified investor in Russia—thresholds and qualification methods.
Mainland China banks offer highly competitive trade finance: rates from 3.1% p.a., flexible tenors and large limits. How UHNW-backed trading firms qualify.
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.
Kraken: trading, Prime, OTC, staking and custody through Kraken Financial. Regulatory entities, Wyoming SPDI status, asset protection, onboarding and limits of public insurance disclosure.
Securitization of paintings through SEC-registered offerings: fees, secondary market, actual returns, and risks of fractional art investment.