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.
Companies & funds
Companies, funds, SPVs, holdings and investment vehicles in key jurisdictions.
Read from purpose to vehicle: business ownership, a joint investment, succession and asset protection call for different structures. Hubs explain the architecture; jurisdiction and vehicle pages show where substance, reporting, control and banking constraints arise.
A vehicle name alone does not decide the outcome: similar labels in two countries can carry different rights, control and disclosure. Separate formation from ongoing governance, tax treatment from company law, and asset protection from the ability to deal with the assets. For a meaningful comparison, identify the founder, beneficiaries and controllers, where decisions are made, which assets enter the structure, and the events that may require a distribution, sale or succession.
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.
Family: Regime, Instrument, Event — Cluster Map
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 under § 2346 BGB and Art. 929 of the French Civil Code, the governance axis and the family office.
AI Roll-Up: Building a Group Through M&A and AI
Five AI roll-up models, choosing a vertical, HoldCo–BidCo–OpCo structure, capital and earn-outs, data rights, the first 100 days and regulatory filters.
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.
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.
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.
Holding Structures: Netherlands, Luxembourg, Cyprus, Singapore, UAE
How to choose a holding jurisdiction: participation exemption in NL, Luxembourg, Cyprus (15% from 2026), Singapore and UAE, the role of treaty network, substance and the 15% global minimum.
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.
Investment Funds: Structure, Management and Launch
How investment funds work: LP and VCC vehicles, Cayman, Delaware, Luxembourg and Singapore, manager licensing, NAV and carried interest, providers and launch.
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.
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 Hub: Company, Residency, Banking, Licenses
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.
How a Trust Works: Settlor, Trustee, Beneficiary, Protector
A trust basics map: settlor, trustee, beneficiaries, protector, legal and beneficial ownership, fiduciary duties, reserved powers and sham risk.
Succession Planning: Wills, Multi-Jurisdiction & Forced Heirship
Cross-border succession planning: situs wills, trusts and foundations, choice of law under Regulation 650/2012, forced heirship, probate and estate taxes.
Private Foundations (Foundations / Stiftung): Liechtenstein, Panama, Jersey
What is a private foundation, how it differs from a trust, and how Liechtenstein Stiftung, Panama Private Interest Foundation, and Jersey Foundations work.
Articles
The EU AI Act After 2 August 2026: Obligations for Law Firms and Family Offices
EU AI Act duties for law firms and family offices from 2 August 2026: AI literacy, Article 50 transparency, Article 99 penalties — high-risk duties from 2 December 2027.
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: Banking Access for Non-Resident Owners
Hong Kong or Singapore for a company account: deposit protection of HK$800,000 vs S$100,000, bank licence types, and what HKMA and MAS require at onboarding.
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.
Cross-Border Divorce Jurisdiction: Where to File and How to Get the Decree Recognised
Grounds of jurisdiction under Regulation (EU) 2019/1111 from 01.08.2022, the race of fora and lis pendens, the English rules after Brexit under s. 5(2) DMPA 1973, recognition of foreign, religious and non-judicial divorces, and why the money does not follow the divorce.
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.
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.
Jersey, Singapore or New Zealand: Choosing a Trust Jurisdiction
A primary-source comparison of three trust jurisdictions: firewall strength (Jersey art. 9 against Singapore s 90 and New Zealand's silence), reserved powers, perpetuity, taxation, disclosure and CRS/CARF timing, trustee licensing and the published JFSC, MAS and IRD tariffs.
DIFC Family Office: The 2023 Regulations, Licensing and the $50M Question
DIFC single family office under the Family Arrangements Regulations 2023: USD 50m aggregate family net assets as a statutory licence condition, no DFSA licence for a pure SFO, DIFC vs ADGM fees, and MD 261/2024 foundation transparency.
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.
MSO: Management Services Organization for Regulated Practices
MSO (Management Services Organization): separating licensed practice from operational platform. Friendly PC and MSA, industry map from medicine to pharmacy, management fee models.
Professional Corporation in the USA: Ownership of Licensed Practice
Professional corporations in the USA: PC, PLLC, PA, RLLP, and design professional corporation. Three admission tests, ownership rules (49% in California, 75% in New York).
Investment Fund Domicile: Jurisdiction, Structure and Launch
How to choose the jurisdiction and legal form of an investment fund: domiciles in the US, Cayman Islands, BVI, Jersey, Luxembourg, Ireland, Singapore, Hong Kong and the Gulf.
Where the Fund Manager Sits: Choosing the Manager's Jurisdiction
Choosing the fund manager's jurisdiction: license thresholds, timelines, substance, tax on management fee and carry, investor access. SG, HK, UAE, UK, US, EU.
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.
The Personal Service Company and IR35
IR35 and the personal service company: Chapters 8 and 10 ITEPA 2003, the Ready Mixed Concrete test, the case law, the offset from 6 April 2024, appeal deadlines, cost, and the owner's move.
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.
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.
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.
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.
Private Aircraft: Registration, Ownership, VAT and Operations
Map of private aircraft registries from M- to N-trust, temporary admission and EU import points, Cape Town and IDERA, economics by class, 2025–2026 regulatory trends and Q/A.
Family Philanthropy: Foundations, DAFs and Cross-Border Giving
How family charitable capital is structured: US private foundations vs DAFs, UK Gift Aid and the 10% IHT threshold, the Stiftung, and cross-border giving.
Fund Finance: Subscription Lines and NAV Facilities
Fund-level debt explained: subscription lines on uncalled commitments, NAV facilities on the portfolio, hybrids and GP lines. IRR impact and LP checklist.
Family Office Economics: Budget, Team and Infrastructure
What an SFO costs in basis points, headcount and pay, what to outsource, and how consolidated reporting, the tech stack and the risk contour actually work.
Matrimonial Property Regimes: What Counts as Marital and Under Which Law
Community of acquests, separation of property and deferred community: default regimes in France, Germany, England, the US and Russia, plus EU Reg 2016/1103.
Fund LPA: Clawback, LPAC and GP Removal
How an LPA protects LPs: clawback and escrow, recycling limits, LPAC powers, for-cause and no-fault removal, key person events and ILPA standards.
Family Office Cybersecurity and Privacy: Access Control and Incident Response
Why family offices are targets: business email compromise, deepfakes, the digital footprint, kidnap & ransom cover, callback verification, the first hour.
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.
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.
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.
Section 13O for a Singapore Single Family Office: 2026 Conditions
Section 13O conditions for Singapore single family offices: S$20m AUM in designated investments, 2 IPs, tiered spending, CDR. Updated July 2026.
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.
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.
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.
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.
Intestate Succession in the UK: Intestacy, Freedom of Testation and Planning
How estates are divided without a will in England and Wales: £322,000 statutory legacy for spouse, freedom of testation and the 1975 Act, 40% inheritance tax and residence-based regime from April 2025.
Intestate Succession in Spain: legítima, foral law and planning
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.
Intestate Succession in France: réserve héréditaire and Planning
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.
Intestate Succession in Italy: legittima, patto di famiglia, and Planning
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.
Hong Kong FIHV: 0% profits tax for the family-owned investment holding vehicle
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.
Intestate Succession in China: Civil Code 2021 and Planning
Two classes of heirs under China's 2021 Civil Code, spousal share, testamentary reform, "necessary portion" (Art. 1141), testamentary trusts, and no inheritance tax.
Intestate Succession in the USA: Intestacy, Elective Share, and Planning
How inheritance is divided 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.
License for Rent: How Business Works Under Someone Else's Regulation
One model across industries: banking without a bank license (BaaS), insurance via fronting, funds on regulatory hosting, crypto and gambling white-label. Where responsibility lies.