Offshore Tax with HTJ.tax

From time to time, structures are presented as being “stronger” or “more private” than a traditional Cook Islands trust. In this episode, we critically examine one such multi-layered structure and place it in its proper context—technical theory vs. regulatory reality.

This is not an endorsement. It is an explanation of how such structures are described, how reporting logic is argued, and why extreme caution is required.

🔎 What This Episode Covers

1️⃣ The Proposed Structural Architecture (High-Level Overview)

The structure is typically described as follows:

• An SPV custodial institution is established

...

Cook Islands trusts are often described as legally robust under offshore law—yet some have still ended badly for settlors in U.S. courts. In this episode, we explain why these outcomes occur, what courts are actually enforcing, and where the real risks lie.

🔎 What You’ll Learn in This Episode:

1️⃣ Why the Assets Often Remain Protected—Yet the Settlor “Loses”

In many U.S. cases, the trust assets themselves remained protected under Cook Islands law and were not seized by creditors.

The problem arose because U.S. courts focused on the conduct of th...

Cook Islands trusts are often marketed as impenetrable asset-protection tools—but U.S. court records tell a more nuanced story. In this episode, we examine why some settlors have failed when courts ordered repatriation, and what “failure” actually means in practice.

Crucially, these cases are not about creditors directly seizing offshore assets. Instead, they center on personal enforcement: courts compelling settlors to act—and punishing non-compliance through contempt sanctions.

🔎 What You’ll Learn in This Episode:

1️⃣ What “Failure” Really Means

When U.S. courts order repatriation and a settlor does not comply, the typical o...

Cook Islands trusts are frequently presented as the strongest form of asset protection available—but they are not immune from criticism or regulatory reality. In this episode, we examine the most common critiques of Cook Islands trusts and explain how modern transparency, enforcement, and court powers can limit their effectiveness if misunderstood or misused.

🔎 In This Episode, You’ll Learn:

1️⃣ Subject to Automatic Exchange of Information

Despite perceptions of secrecy, Cook Islands trusts are not invisible.

They are subject to FATCA and CRS, meaning information can be automatically exchanged with tax authorities...

Cook Islands trusts are often described as the “fortress” of asset protection—but what does that really mean in legal terms? In this episode, we break down the structure using a simple metaphor to explain how Cook Islands trust law creates multiple, layered defenses around assets.

This is not about secrecy or evasion—it’s about legal architecture, process, and rule-of-law safeguards.

🔎 In This Episode, You’ll Learn:

🏰 The Moat: Re-Litigation in the Cook Islands

Any creditor claim must be re-litigated entirely in the Cook Islands under local law.

Foreign court judg...

Cook Islands trusts are powerful asset-protection tools, but they are not magic shields. In this episode, we take a clear-eyed look at the limitations of Cook Islands trusts—what they are not designed for, and why understanding these boundaries is essential for anyone considering this structure.

🔎 In This Episode, You’ll Learn:

1️⃣ Not a Tool for Existing Creditors

Cook Islands trusts are intended to protect against future, unknown claims.

If assets are transferred after a lawsuit has started or when a claim is already foreseeable, Cook Islands courts are likely to rule agains...

Cook Islands trusts are not one-size-fits-all solutions. They are typically used by individuals who face elevated legal, professional, or commercial risk and who require a strong, legally robust framework for long-term asset protection. In this episode, we explain who commonly uses Cook Islands trusts—and why.

🔎 In This Episode, You’ll Learn:

1️⃣ High-Risk Professionals

Professionals such as:

• Doctors and surgeons

• Architects and engineers

• Lawyers and legal advisors

often face heightened exposure to malpractice or professional liability claims. Cook Islands trusts are frequently considered as part of pre-emptive, c...

Cook Islands trusts are widely regarded as one of the most robust asset-protection vehicles in the world—but why? In this episode, we break down the core legal features that give Cook Islands trusts their strength, focusing on what is expressly provided under local law and how these mechanisms operate in practice.

This discussion is about understanding legal design and risk management, not shortcuts—and why timing, intent, and compliance remain essential.

🔎 In This Episode, You’ll Learn:

1️⃣ Irrevocable & Spendthrift Design

• Irrevocability:

In most cases, the settlor gives up the power to re...

Why do Cook Islands trusts continue to be referenced in serious asset-protection planning discussions? In this episode, we break down the core legal protections that distinguish Cook Islands trusts from other offshore structures—and why they are often considered the gold standard in high-risk asset protection planning.

We focus on what is actually written into law, specifically under the International Trusts Act 1984, and how these principles operate in practice.

🔎 In This Episode, You’ll Learn:

1️⃣ Why Foreign Judgments Don’t Travel

Cook Islands law contains a statutory prohibition on enforcing foreign judgments aga...

Portugal’s high level of vacant housing continues to attract political and public attention—but what is actually happening at policy level? In this episode, we explore the government measures currently under discussion, what has (and hasn’t) been decided, and why uncertainty remains.

🔎 In This Episode, You’ll Learn:

1️⃣ Why Vacant Housing Remains a Policy Priority

National and municipal authorities recognise that long-term vacancy affects housing availability, affordability, and urban regeneration—particularly in high-demand areas.

2️⃣ Measures Currently Being Evaluated

Authorities are actively discussing:

• Fiscal instruments, including potential tax-based inc...

Estate planning in Portugal follows a civil law tradition that places strong protections around family inheritance rights. In this episode, we explain how forced heirship works, why it matters, and what it means for anyone preparing a will that involves Portuguese assets.

This is a crucial topic for international families, property owners, and advisors navigating cross-border succession planning.

🔎 In This Episode, You’ll Learn:

1️⃣ What Forced Heirship Means in Portugal

Portuguese law protects the mandatory share of certain heirs—known as legitimate heirs. These rights are enshrined in the Civil Code and cannot...

When inheriting property in Portugal, taxes are often a major concern—especially for international families. In this episode, we clarify how Stamp Duty (Imposto do Selo) applies to inherited property, who is exempt, and why compliance matters even when no tax is payable.

🔎 In This Episode, You’ll Learn:

1️⃣ The 10% Stamp Duty Rule

Portugal does not impose a traditional inheritance tax. Instead, inheritances fall under Imposto do Selo, generally charged at a flat rate of 10% on the value of assets transferred by inheritance.

2️⃣ Who Is Usually Exempt

The following beneficiaries a...

When inheriting property in Portugal, understanding the costs involved is just as important as understanding the legal steps. In this episode, we break down the typical fees heirs can expect when completing a habilitação de herdeiros and transferring or registering inherited property.

🔎 In This Episode, You’ll Learn:

1️⃣ Cost of a Basic Habilitação de Herdeiros

According to official fee schedules published on gov.pt, a straightforward habilitação procedure generally costs in the low hundreds of euros.

This typically applies when:

• The estate is simple

• Heirs are in agreem...

When inheriting property in Portugal, taxes are often a major concern—especially for international families. In this episode, we clarify how Stamp Duty (Imposto do Selo) applies to inherited property, who is exempt, and why compliance matters even when no tax is payable.

🔎 In This Episode, You’ll Learn:

1️⃣ The 10% Stamp Duty Rule

Portugal does not impose a traditional inheritance tax. Instead, inheritances fall under Imposto do Selo, generally charged at a flat rate of 10% on the value of assets transferred by inheritance.

2️⃣ Who Is Usually Exempt

The following beneficiaries a...

Portugal is often described as facing a housing shortage—yet walk through many towns and cities and you’ll see countless empty homes. So what explains this apparent contradiction? In this episode, we unpack the structural, legal, and economic reasons behind Portugal’s high number of vacant properties.

🔎 In This Episode, You’ll Learn:

1️⃣ Inheritance and Legal Bottlenecks

A significant number of properties remain empty because they are tied up in:

• Ongoing inheritance proceedings

• Disputes between heirs

• Delays in probate or property registration

Until these issues are resolved...

When international families own property or other assets in Portugal, one critical question often arises: Will a foreign will be recognised under Portuguese law? In this episode, we clarify how Portugal treats foreign wills—and why careful estate planning is essential to avoid unintended outcomes.

🔎 In This Episode, You’ll Learn:

1️⃣ What Types of Wills Portuguese Law Recognises

Portuguese law formally recognises public wills and closed wills, each with specific formal requirements.

2️⃣ Are Foreign Wills Valid in Portugal?

Foreign wills may be valid in relation to Portuguese assets, provided they meet appli...

Buying property in Portugal involves more than just the purchase price. In this episode, we walk through the key taxes and fees every buyer—local or foreign—should budget for when acquiring real estate in Portugal.

Understanding these costs upfront helps avoid surprises and ensures smoother transactions.

🔎 In This Episode, You’ll Learn:

1️⃣ IMT – Property Transfer Tax

The main tax payable on acquisition is IMT (Imposto Municipal sobre as Transmissões Onerosas de Imóveis).

• IMT is calculated based on the type of property (urban, rural, residential, etc.)

• The rate incre...

Inheritance taxation is one of the most common—and misunderstood—questions when dealing with estates in Portugal. In this episode, we clarify how Portugal actually taxes inheritances and what families should expect when assets pass to the next generation.

The answer may surprise many international families.

🔎 In This Episode, You’ll Learn:

1️⃣ Why Portugal Has No Traditional Inheritance Tax

Portugal does not impose a conventional inheritance or estate tax like many other countries. There is no progressive inheritance tax regime applied to estates as a whole.

...

When someone dies owning assets in Portugal, one legal step is often unavoidable: the habilitação de herdeiros. In this episode, we explain what this procedure is, why it matters, and when families must complete it to move forward with estate administration.

Understanding this process early can save time, reduce friction among heirs, and prevent costly delays.

🔎 In This Episode, You’ll Learn:

1️⃣ What the Habilitação de Herdeiros Is

It is the formal declaration of heirs under Portuguese law, identifying:

• All legal...

When someone dies owning assets in Portugal, one legal step is often unavoidable: the habilitação de herdeiros. In this episode, we explain what this procedure is, why it matters, and when families must complete it to move forward with estate administration.

Understanding this process early can save time, reduce friction among heirs, and prevent costly delays.

🔎 In This Episode, You’ll Learn:

1️⃣ What the Habilitação de Herdeiros Is

It is the formal declaration of heirs under Portuguese law, identifying:

• All legal...

Navigating inheritance procedures in a foreign country can feel overwhelming, especially when real estate is involved. In this episode, we unpack the very first step families must take when someone passes away owning property in Portugal.

The Portuguese succession process has specific legal requirements, and understanding them early can prevent delays, disputes, and costly mistakes.

🔎 In This Episode, You’ll Learn:

1️⃣ Why the Will Certificate Matters

The process begins with requesting the will certificate from the IRN (Instituto dos Registos e do Notariado).

As global transparency frameworks expand to include real estate, many high-net-worth families and advisors are reassessing how property ownership structures intersect with international reporting obligations. In this episode, we explore how common legal structures—such as SPVs, holding companies, and trusts—affect visibility under emerging information-exchange systems like the IPI MCAA.

We focus on the principles, not loopholes: understanding what is reportable, how ownership layers are treated, and why relying on non-participating jurisdictions raises significant regulatory, ethical, and reputational considerations.

🔎 What You’ll Learn in This Episode:

1️⃣ How Property...

Duration: 00:07:29

As countries adopt the IPI MCAA framework, one of the most important questions is: What exactly will be shared?

In this episode, we break down the full scope of information exchanged between tax authorities regarding immovable property—covering the asset itself, its transactions, its owners, and any related income.

This is the most detailed international real estate reporting standard ever proposed, and understanding its components is essential for advisors, compliance teams, and internationally mobile individuals.

🔎 What You’ll Learn in This Episode:

1️⃣ Information About the Property It...

Duration: 00:03:32

How often will countries exchange real estate information under the new transparency framework? In this episode, we break down the reporting timelines built into the IPI MCAA (Immovable Property Information Multilateral Competent Authority Agreement)—and what they mean for tax authorities, advisors, and internationally mobile property owners.

The agreement sets out two types of exchanges: a one-off exchange of historical property holdings and annual exchanges covering new acquisitions, disposals, and recurrent income. Understanding the timing requirements is crucial for compliance and system readiness.

🔎 What You’ll Learn in This Episode:

Reciprocity sits at the heart of global tax transparency. Without it, information exchange systems would be unbalanced, inconsistent, and difficult to implement. In this episode, we unpack how reciprocity works specifically within the IPI MCAA (Immovable Property Information Multilateral Competent Authority Agreement) and what makes this framework unique.

Unlike other exchange-of-information agreements, the IPI MCAA allows jurisdictions to provide Readily Available Information on an “as is” basis while letting receiving jurisdictions decide whether they want to participate in one or both of the reporting modules. This flexibility makes the system more inclusive—while still preserving the essential princi...

As governments work to strengthen global tax transparency, the exchange of real estate information has become a new priority. But instead of creating complex new reporting systems, the IPI MCAA (Immovable Property Information Multilateral Competent Authority Agreement) takes a more practical approach: it focuses on Readily Available Information—data that tax authorities already possess and can share quickly.

In this episode, we break down why this approach was chosen, what counts as “readily available,” and how the framework works in practice.

🔎 In This Episode, You’ll Learn:

• Why the IPI M...

As global tax authorities continue to strengthen transparency frameworks, real estate has emerged as a critical area in need of more consistent reporting. Many jurisdictions already hold valuable property data—transactions, ownership records, and recurring income—but these details are often siloed, inaccessible, or exchanged inconsistently across borders.

In this episode, we explore how developing a common legal and operational approach can dramatically improve short-term tax transparency by enabling governments to share Readily Available Information on immovable property more efficiently.

At the heart of this effort is the Immovable Property Information Multilateral Comp...

Over the past decade, global tax transparency has undergone a major transformation. Since 2010, new international standards and agreements have dramatically lowered the barriers to sharing tax information across borders. Now, with real estate increasingly recognized as a vehicle for hiding undeclared wealth, governments are moving to strengthen reporting frameworks even further.

In this episode, we unpack the legal foundation behind the exchange of real estate information—focusing on the emerging Immovable Property Information (IPI) MCAA, a multilateral agreement designed to enhance collaboration among jurisdictions that choose to participate.

🔎 In This Episode, You’ll Lear...

Global tax transparency didn’t happen overnight—it began with a bold statement from G20 leaders in 2009 to end bank secrecy. That declaration set the stage for the Exchange of Information on Request (EOIR) standard, empowering tax authorities to access key financial data, accounting records, and even beneficial ownership details tied to assets like real estate.

In this episode, we explore how the movement toward transparency has evolved, and how India’s persistent advocacy has pushed the conversation even further. Building on years of requests, the G20 in 2023 officially recommended expanding the Automatic Exchange of Information (AEOI) to inc...

Why is real estate becoming the next major focus in global tax transparency? In this episode, we break down the growing push—led strongly by India within the G20—to include non-financial assets like property in the Automatic Exchange of Information (AEOI) framework.

For years, the global system has focused almost exclusively on financial accounts through CRS. But new data shows a rising challenge: cross-border property ownership is increasing and is often underreported, creating blind spots that allow undeclared wealth to slip through existing reporting rules.

🔎 Inside This Episode:

•...

Around the world, governments are quietly shifting their tax strategies — moving away from corporate taxation and turning their attention to private wealth. As inequality widens and traditional tax bases shrink, high-net-worth individuals, global entrepreneurs, and mobile “tax nomads” are finding themselves increasingly under scrutiny.

In this episode, we break down why wealthy families are becoming the new tax target, what governments are planning next, and how internationally mobile individuals can protect themselves through smarter planning and stronger compliance.

🔎 What You’ll Learn:

• The global pivot toward wealth taxes

<...

In this episode, we unpack everything you need to know about Power of Attorney (POA) validity in the UAE—how long it lasts, when it expires, and why keeping it updated is crucial.

📝 Key Highlights:

Timing matters when it comes to probate in the UAE—and having a Will can make all the difference.

✅ With a Will

Probate is streamlined, usually wrapping up in 6–8 weeks (about 2 months). If the death certificate comes from outside the UAE, allow an extra month for attestations. The process is clear, predictable, and much less stressful for your loved ones.

⚠️ Without a Will

Things get complicated. Sharia law inheritance rules, identifying legal heirs, and family discussions can extend probate to 6 months or more. Without clear instructions, the risk of delays...

Your life changes—and your Will should change with it.

As a general rule, it’s smart to review your Will every 5 years. If you like to stay especially organized, a 3-year check-in works even better. Most UAE Wills already include backup beneficiaries, executors, and guardians, but a periodic review ensures everything still reflects your real-world situation.

🔔 When You Must Review Immediately

Certain life events shouldn’t wait for the next check-in. Update your Will right away if you experience:

Life circumstances change, and your Will may need to be updated. How you do this depends on where the Will is registered:

DIFC Will

Mainland Courts (ADJD & Dubai Courts)

Preparing a Will in the UAE is a straightforward process, whether you choose DIFC, ADJD, or Dubai Courts. The key is gathering the correct documents before registration. Here’s what you need:

1. Identification for All Individuals Named in the Will

You must provide ID for every person mentioned in the Will, including:

If someone doesn’t have an Emirates ID, a passport copy is sufficient. All documents must be clear scanned copies with all four...

A Power of Attorney (POA) is often confused with a Will, but the two serve entirely different purposes.

POA vs. Will

A POA is valid only during the lifetime of both the person granting it and the person receiving it.

If either party passes away, the POA becomes immediately invalid. At that point, the Will takes over for probate and asset distribution.

This means a POA cannot be used for post-death matters and does not replace a Will in any way.

When a...

Duration: 00:02:49

A UAE Will can cover a wide range of assets, giving individuals full control over how their estate is distributed and ensuring a smooth probate process. Wills are typically drafted broadly so that both current and future assets are included without requiring frequent updates.

Common Assets Included in a UAE Will

In the UAE, the assets most commonly covered include:

A Power of Attorney (POA) is one of the most useful legal tools in the UAE, but it is often misunderstood. A POA does not replace a Will, and the two documents serve completely different purposes.

POA vs. Will

A Power of Attorney is valid only during the lifetime of both:

If either...

You can absolutely keep your home-country Will valid while living in the UAE. In fact, many expatriates maintain a foreign Will for overseas assets while using a UAE Will for local property and guardianship. There are two recognized methods to ensure your foreign Will remains legally effective:

1. DIFC Will Covering Foreign Assets

A DIFC Will can include assets located outside the UAE, provided the foreign jurisdiction accepts a DIFC-issued probate order. Because the DIFC operates under a common-law framework, it aligns naturally with countries such as:

The UAE allows a broad range of individuals to register a Will, provided they meet certain basic legal criteria. To register a Will, a person must be:

Beyond these core requirements, eligibility depends on residency status and asset location.

1. UAE Residents

Anyone holding a UAE residence visa—regardless of nationality or religion—may register a Will in any of the recognized jurisdictions:

Registering a Will in the UAE is a straightforward process, but several essential requirements must be met. The testator must be at least 21 years old, be of sound mind, and must act voluntarily, free from pressure or undue influence.

UAE Wills are typically drafted in broad, comprehensive terms to cover both existing assets and any future assets acquired after the Will is signed. This ensures that newly purchased property, bank accounts, or investments are automatically included without needing frequent amendments.

What a Standard UAE Will Includes

A typical Will contains...

When registering a Will in the UAE, individuals can choose from three primary jurisdictions—ADJD, Dubai Courts, and DIFC. Each offers different advantages in terms of cost, process, language, and flexibility.

1. ADJD (Abu Dhabi Judicial Department)

Best for: Cost efficiency, full virtual process, expat Muslims

When a person passes away in the UAE, the procedure that follows depends heavily on whether a valid Will is in place.

With a Will

If a Will exists, the process is significantly simpler and more predictable.

In the UAE, having a legally registered Will is not optional — it is crucial. Without one, a person’s estate is automatically governed by Sharia inheritance rules, which impose predetermined shares for heirs regardless of the individual’s personal wishes.

When someone dies without a Will in the UAE, several complications follow:

Custodial institutions and fiduciary structures may both “hold assets,” but legally they are completely different. The distinction comes down to the relationship, the level of discretion, and who is allowed to act on behalf of the owner. Under EU regulations, this difference determines why custodians remain allowed for Russians, while fiduciary services are banned.

A Simple Analogy: Safe Deposit Box vs. Personal Chef

Custodial Institution = Safe Deposit Box Manager

Top Company (Custodial Institution)

While custodians and fiduciaries are closely related, they serve fundamentally different roles in wealth management and trust structures. Importantly: all fiduciaries are custodians in some sense, but not all custodians are fiduciaries.

1. Custodial Institution (“Vault Keeper”)

Role: Safeguard and protect client assets.

Core Function: Holding assets securely against loss, theft, or error.

Key Responsibilities:

In this episode, we break down the EU’s crackdown on Russian-linked trusts — now widely referred to as “zombie trusts” — following amendments to Article 5m of Council Regulation (EU) 833/2014. These rules have rendered many existing structures legally unserviceable and have effectively shut the door to new trust formation involving Russian nationals or entities.

Key Points Covered:

1. What Article 5m Now Prohibits

Under the amended regulation, EU persons and service providers are barred from registering, hosting, or managing trusts where any of the following are involved:

In this episode, we explore how wealthy Russians are responding to the tightening global network of financial transparency — particularly the Common Reporting Standard (CRS) and the Automatic Exchange of Information (AEOI). These frameworks have dramatically reduced financial secrecy, forcing individuals to adapt quickly or risk exposure to Russian tax authorities and enforcement actions.

Key Discussion Points:

We examine why many wealthy Russians are especially worried about global information-exchange regimes. The Common Reporting Standard (AEOI/CRS) and Exchange-on-Request (EoR) create layered visibility that can expose residency, assets, and financial flows — with consequences ranging from tax assessments to targeted investigations. Host countries that once offered anonymity now participate in automatic reporting, and requests from foreign authorities can probe ownership, trusts, and transaction histories. For those with ties to Russia, the combination of CRS reporting and Russia’s own residency rules can create unexpected exposure and legal risk.

Key Points Covered:

In this episode, we explore how certain jurisdictions remain outside the reach of CARF (Crypto-Asset Reporting Framework) — and why Svalbard and UK non-resident trusts continue to offer unique confidentiality advantages.

Key Insights:

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

In this episode, we break down when crypto transactions become reportable under the Crypto-Asset Reporting Framework (CARF) — and why not every wallet movement or exchange triggers a filing.

Key Takeaways:

In this episode, we unpack how the Crypto-Asset Reporting Framework (CARF) differs from its predecessors — FATCA and CRS — and why these differences matter for compliance and reporting transparency in the crypto era.

Key Takeaways:

The Crypto-Asset Reporting Framework (CARF) is designed to bring order, oversight, and accountability to the fast-moving world of digital assets. Its goals align closely with global efforts to prevent tax evasion, money laundering, and the misuse of crypto for illicit activity.

Key Objectives:

The Crypto-Asset Reporting Framework (CARF) represents the next major evolution in global financial transparency. It builds upon a lineage that started with FATCA, evolved through the Common Reporting Standard (CRS), and now extends to the world of digital assets.

The Evolution:

For many expats and entrepreneurs, maintaining or managing a foreign company while living in Portugal seems straightforward — but Portugal’s corporate tax rules can make things more complex than expected.

Key Point:

Unlike some countries that rely heavily on the “Place of Effective Management” (POEM) as a tie-breaker rule, Portugal uses “effective management” as a primary test for determining corporate tax residency.

Here’s what that means:

If you’re planning to live, work, or even spend extended time in Portugal, there’s one acronym you’ll hear again and again — NIF.

What Is a NIF?

The NIF (Número de Identificação Fiscal) is your personal tax identification number — a nine-digit code issued by the Portuguese Tax Authority (Autoridade Tributária e Aduaneira). Think of it as your financial identity in Portugal.

Who Needs a NIF?

It’s not just for taxpayers or residents — practically anyone engaging in official or financial activity in Portug...

It’s easier than many people think to become a tax resident in Portugal by accident — and the consequences can be significant.

What Happens If You Accidentally Become a Resident:

How...

Portugal offers a unique incentive to encourage talented professionals to return home — but it’s not widely known outside the tax and legal community.

The Opportunity:

If you’ve been living abroad and decide to re-establish tax residency in Portugal, you may qualify for a 50% income tax deduction for five years.

How It Works:

While Portugal’s tax advantages often steal the spotlight, there’s much more that makes the country one of Europe’s most desirable retirement destinations.

Why Retirees Love Portugal:

Many expats feared they missed the window to apply for Portugal’s Non-Habitual Resident (NHR) regime after its phase-out. However, the 2024 Budget Law introduced extensions for those who had already begun their move before the deadline.

If you took concrete relocation steps by December 31, 2023, you may still qualify under the old NHR regime.

Who May Still Be Eligible:

Portugal is entering a new era of tax incentives with the introduction of the IFICI (Incentivo Fiscal à Investigação Científica e Inovação) — also known as NHR 2.0.

This program replaces the long-standing Non-Habitual Resident (NHR) regime and reflects Portugal’s pivot toward innovation, entrepreneurship, and high-value economic activity.

Key Highlights:

Portugal offers a variety of tax and financial incentives to encourage property purchases, urban rehabilitation, and rental housing. Here’s a breakdown of the main programs:

1. Permanent IMT Exemption for Primary Residence

2. Reduced VAT (IVA) for New Construction

...

If you’ve moved to Portugal or become tax resident there, one of the most common questions is: “Do I have to declare my assets abroad?” The answer is yes — but it’s important to understand what that really means.

Key Requirement:

Under Portuguese law, residents must file the “Modelo 10 – Declaração de Início de Atividade e Identificação de Contas e Aplicações no Estrangeiro.”

This is an informational declaration, not a tax return. It notifies the Portuguese Tax Authority (AT) that you hold foreign accounts or investments...

If you’re earning income from more than one country, one of your biggest fears is being taxed twice. The good news? Portugal has strong safeguards in place to prevent that. In this episode, we break down how double taxation relief works for expats and international investors.

Key Frameworks for Relief:

1. Double Taxation Treaties (DTTs):

Portugal has signed DTTs with over 80 countries, most following the OECD Model Convention. These treaties decide which country gets taxing rights over specific income types—like dividends, pensions, or capital gains—so the sa...

Becoming a tax resident in Portugal doesn’t just change your address—it changes your entire tax universe. Once you’re classified as a Portuguese tax resident, all of your worldwide income becomes subject to Portuguese taxation. In this episode, we explain exactly what that means, who it affects, and what planning opportunities exist.

How It Works:

Once tax residency is established, Portugal consolidates all global income and applies its national tax system.

Income Tax Rates (2025):

When is the smartest time to move to Portugal from a tax perspective? Timing your move can make the difference between a seamless transition and a year of double taxation headaches. In this episode, we unpack the tax “ghosts” that follow people who move too soon — or too late.

Major Pitfalls and Residency Traps:

Owning property in Portugal doesn’t automatically make you a tax resident — but it can create financial obligations you need to understand. In this episode, we break down the key taxes and costs tied to property ownership in Portugal.

Key Financial Considerations:

Portugal’s tax system includes a split-year rule — an important provision for anyone moving into or out of the country. Instead of being taxed as a full-year resident, Portugal lets you divide the tax year into two parts.

How It Works:

Tax residency is the key factor that determines when your income becomes taxable in Portugal. While the 183-day rule is the most widely recognized test, Portuguese law also considers where your home, work, and personal life are centered.

You Are Considered a Tax Resident in Portugal If You Meet Any of the Following:

Portugal’s tax landscape is entering a new phase of transition. While the previous government focused on the housing crisis and tightening tax benefits for foreigners, the current administration has signaled a clear pivot toward supply-side reforms — prioritizing lower personal and corporate taxes to drive investment and growth.

Key Policy Changes Under Consideration:

Banking in Cyprus has a complex history, shaped by a dramatic crisis and a remarkable transformation. The Cypriot banking sector has emerged from that period leaner, stronger, and far more resilient. Although it no longer functions as a high-risk, high-liquidity offshore hub, it has successfully repositioned itself as a credible and well-regulated European financial centre.

Today, Cyprus stands as an attractive destination for international businesses and individuals — particularly those with genuine economic activity in or through the island — who value the blend of EU regulatory security, a favourable tax environment, and high-quality professional services.

Key Take...

In this episode, we unpack the rules that determine personal tax residency in Cyprus, one of the most sought-after jurisdictions for individuals looking to optimize their global tax position.

Cyprus offers two distinct routes to tax residency — the classic 183-day rule and the flexible 60-day rule, making it a uniquely accessible and compliant destination for entrepreneurs, investors, and internationally mobile professionals.

We’ll explain how each rule works, what conditions must be met, and the tax advantages available once you become a Cyprus tax resident.

📅 The Two Routes...

Duration: 00:06:02

In this episode, we explore why Cyprus has become one of the most attractive jurisdictions for establishing international trusts, particularly for high-net-worth individuals and families seeking to manage wealth efficiently and securely.

We’ll break down the Cyprus International Trusts (CIT) Law, highlight the tax advantages, and explain how Cyprus balances asset protection, tax neutrality, and international compliance — making it a compelling choice compared to other trust jurisdictions.

⚖️ Background: The Cyprus International Trust (CIT)

The Cyprus International Trusts Law provides a robust legal framework for both EU and non-EU individuals to creat...

In this episode, we explore how Cyprus’s new defensive tax measures are reshaping the landscape for non-resident companies. These measures, including a General Anti-Abuse Rule (GAAR) and new substance requirements, target artificial structures designed to route payments through low-tax jurisdictions without real economic presence.

We unpack what this means for corporate groups, holding structures, and international tax compliance — and how businesses can adapt before the 2026 implementation deadline.

⚖️ The Rule in Focus

Cyprus has introduced a general anti-abuse rule allowing tax authorities to disregard arrangements that:

In this episode, we explore the General Anti-Abuse Rule (GAAR) introduced in Cyprus under the EU’s Anti-Tax Avoidance Directive (ATAD). The GAAR serves as a broad safeguard against aggressive tax planning that may fall outside specific anti-avoidance rules like transfer pricing, CFC, or interest limitation provisions.

We break down how Cyprus applies the GAAR to non-genuine arrangements, what counts as “economic reality,” and how the rule fits into the broader international move toward substance-based taxation.

⚖️ The Rule in Focus

Under the Cyprus GAAR, any arrangement or series of arrangements that:

In this episode, we unpack Cyprus’s Controlled Foreign Company (CFC) Rule — a key anti-avoidance measure that ensures profits shifted to low-tax jurisdictions remain subject to taxation where real economic activity occurs.

We explain how Cyprus applies its CFC rule under the EU Anti-Tax Avoidance Directive (ATAD), what counts as a “non-genuine arrangement,” and when exemptions apply.

🧩 Key Topics Covered

In this episode, we break down Cyprus’s Interest Limitation Rule (ILR) — a cornerstone of the EU’s Anti-Tax Avoidance Directive (ATAD) framework.

The rule is designed to curb profit shifting through excessive interest deductions and ensure Cyprus remains a transparent, compliant, and competitive jurisdiction.

We’ll explain how the 30% EBITDA cap works, what the main exemptions are, and how businesses can manage compliance effectively under this regime.

🧩 Key Topics Covered

In this episode, we explore Cyprus’s new defensive tax measures targeting payments to low-tax and EU-blacklisted jurisdictions, set to take effect from 1 January 2026.

These measures mark a major compliance shift, aligning Cyprus with OECD and EU anti-tax avoidance standards while fulfilling commitments under the EU Recovery and Resilience Plan.

We’ll break down what’s changing, how these rules apply to dividends, interest, and royalties, and what global investors and corporate structures need to consider before the effective date.

🧩 Key Topics Covered

In this episode, we unpack Cyprus’s Non-Domicile (Non-Dom) tax regime — one of the most strategic tax residency options in Europe for high-net-worth individuals. Introduced in July 2015, this regime continues to position Cyprus as a compliant, transparent, and highly attractive jurisdiction for international relocation and wealth structuring.

We’ll explain what it means to be a “non-dom,” how to qualify, and the real tax advantages that make Cyprus one of the leading destinations for global citizens seeking efficient tax residency.

🧩 Key Topics Covered

In this episode, we break down Portugal’s newly updated list of “tax haven” jurisdictions for 2025, which now excludes Hong Kong, Liechtenstein, and Uruguay. These updates reflect Portugal’s ongoing effort to align its tax transparency framework with OECD and EU standards, while maintaining one of Europe’s more comprehensive blacklists.

We explore what this means for investors, companies, and advisors working with Portuguese structures — and how this change fits within broader global blacklisting trends.

🧩 Key Topics Covered

In this episode, we break down Portugal’s newly updated list of “tax haven” jurisdictions for 2025, which now excludes Hong Kong, Liechtenstein, and Uruguay. These updates reflect Portugal’s ongoing effort to align its tax transparency framework with OECD and EU standards, while maintaining one of Europe’s more comprehensive blacklists.

We explore what this means for investors, companies, and advisors working with Portuguese structures — and how this change fits within broader global blacklisting trends.

🧩 Key Topics Covered

In this episode, we explore how U.S. investors are using Self-Directed IRAs (SDIRAs) to participate in Golden Visa programs across Europe — particularly in Portugal, Greece, and Hungary. While these structures offer exciting possibilities for diversification and residency planning, they also introduce significant IRS compliance risks and potential UBIT/UBTI exposure that many investors overlook.

We unpack the intersection between U.S. retirement law and foreign investment migration programs, highlighting what advisors and investors need to know before funding a Golden Visa through a retirement vehicle.

🧩 Key Topics Covered

The Wyden Draft Bill, formally part of the Modernization of Derivatives Tax Act discussion, poses a potential existential threat to the Private Placement Life Insurance (PPLI) industry. While 2025 has been dominated by discussions around the One Big Beautiful Bill Act (OBBBA), it’s crucial to revisit 2024’s legislative developments, particularly Senator Ron Wyden’s draft proposal, which could fundamentally alter the tax treatment of derivatives—and, by extension, PPLI structures relied upon by ultra-high-net-worth individuals.

In this episode, we break down the key provisions of the draft bill, explain how they intersect with PPLI, and discuss the possible...

The One Big Beautiful Bill Act (OBBBA) represents one of the most significant shifts in U.S. international tax policy since the 2017 Tax Cuts and Jobs Act (TCJA). By transitioning from the Global Intangible Low-Taxed Income (GILTI) regime to the Net CFC Tested Income (NCTI) system, Congress not only simplified the rules—but also brought the U.S. statutory rate on international income closer to global standards under Pillar Two.

In this episode, we unpack what that alignment means, how it affects U.S. multinational corporations, and why the OBBBA’s rate reforms may signal the end of A...

When the Tax Cuts and Jobs Act (TCJA) repealed section 958(b)(4) back in 2017, it unleashed chaos across the cross-border tax landscape. The repeal allowed downward attribution from foreign to U.S. persons — causing hundreds of unintended Controlled Foreign Corporation (CFC) classifications and widespread compliance headaches.

Now, with the One Big Beautiful Bill Act (OBBBA) of 2025, section 958(b)(4) is finally restored — and a new section 951B introduced — providing a more surgical fix for the original “de-control” problem Congress had aimed to solve.

This episode explores what’s changed, what’s been fixed, and what tax profe...

The One Big Beautiful Bill Act (OBBBA) quietly rewrote one of the most consequential areas of U.S. international tax — rebranding GILTI (Global Intangible Low-Taxed Income) as NCTI (Net CFC Tested Income).

But behind the name change lies a profound policy shift: from a hybrid territorial system to a quasi-worldwide model designed to align—at least cosmetically—with the OECD’s global minimum tax.

In this episode, we unpack what really changed, what didn’t, and why it matters for multinationals, policymakers, and tax planners.

🧩 Key Topics Covered

In 2024, headlines screamed of a millionaire “exodus” from the UK and other countries—10,900+ news pieces carried the story. The supposed flight of the rich was even credited with pressuring the UK Labour government to soften tax reform plans.

But here’s the catch: the narrative rests almost entirely on a single report from Henley & Partners, a firm that sells residence-by-investment schemes.

A review by the Tax Justice Network, with Patriotic Millionaires UK and Tax Justice UK, shows the numbers don’t stack up:

When does technical advice cross into criminal risk—and how can advisors protect themselves?

If an advisor tells a U.S. client:

“Yes, Svalbard’s unique status means a financial institution there may not report to the IRS under FATCA. But this does not eliminate your personal obligations. You must still report on FBAR, Form 8938, and Forms 3520/3520-A—and failure to file carries severe penalties.”

That advice is accurate, complete, and defensible. The advisor is informing, not concealing. The key element of willfulness—intent to defraud—is missing.

But...

Can an advisor get into trouble for giving technically true—but incomplete—advice? Under FATCA, the answer is yes.

Take the example of Svalbard. Norway has a FATCA Model 1 IGA with the U.S., but Svalbard is excluded from the treaty definition of “Kingdom of Norway.” That means a financial institution in Svalbard could, in theory, be treated as a non-participating foreign financial institution.

The problem arises when an advisor uses that narrow fact to suggest a broader loophole, while leaving out critical context. That transforms a technical truth into a misleading strategy...

Owning foreign accounts or assets isn’t illegal, and it’s not inherently unlawful to fall outside FATCA’s scope. The real issue is knowing what counts as a reportable asset and making sure you’re not failing to disclose something that is covered.

FATCA is primarily an information-reporting regime. For individuals, this means filing Form 8938 (Statement of Specified Foreign Financial Assets) if the value of certain foreign assets exceeds set thresholds. These “specified assets” include accounts at foreign banks or brokerages, as well as stock in foreign corporations.

Not everything is reportable...

An Expanded Affiliated Group (EAG) is defined under Code section 1504(a) and Treas. Reg. §1.1471-5(i). It generally means one or more chains of entities connected through ownership by a common parent. Normally, the parent must directly own more than 50% of another member’s stock or equity interests.

In FATCA, the EAG rules are designed to prevent avoidance of reporting obligations. The “one bad apple” rule applies—if any member of the group is a non-participating FFI, then no member can claim participating FFI status.

While the definition is based on corporate ownership...

Between 2017 and 2019, the OECD published FAQs and addendums to CRS to close loopholes—such as residence by investment, broad-based retirement plans, nil-value reporting on settlors, and the treatment of cash. FATCA, however, never addressed these loopholes. Eventually, the OECD abandoned the “whack-a-mole” approach and instead introduced Mandatory Disclosure Rules (MDR). But MDR was largely ineffective: few countries implemented it, and promoters in non-participating jurisdictions or under lawyer privilege were exempt.

Example: a UK non-resident trust classified as a custodial institution with a trustee in Svalbard. It owns an investment entity company but reports nil, since the equity intere...

CRS and FATCA treat non-participating institutions very differently. Under CRS, non-participating Investment Entities are classified as Passive NFEs, meaning the paying agent must look through to the controlling persons. FATCA, on the other hand, penalizes non-participating FFIs that fail to register for a GIIN by imposing a 30% withholding tax on U.S.-sourced payments like dividends, interest, or asset sale proceeds. FATCA also pressures FFIs to close accounts of non-participating FFIs. However, FATCA’s reach is limited where no U.S.-sourced payments are received, such as when a custodial institution only holds company shares.

#FATCA #CRS #Gl...

Financial institutions do not report on account holders that are themselves financial institutions. This enables chains of entities, with each level classified as a financial institution. The weakness of AEoI arises when the top-level entity is a non-participating financial institution. FATCA and CRS only weakly address this vulnerability, leaving opportunities to establish structures that remain non-reportable.

The UAE has become a leading hub for Foundations, especially in DIFC, ADGM, and RAK ICC. These structures blend trust-like asset protection with company-style governance, making them ideal for families and businesses. A Foundation is a distinct legal entity with no shareholders, governed by a Council through its Charter and private By-laws. Assets are contributed by a Founder, with an optional Guardian ensuring oversight. Their flexibility, global appeal, and strong governance standards make them powerful tools for asset protection, succession planning, and wealth management.

UK trust structures offer unique privacy and asset protection benefits. Unlike the FATF model, the UK relies on the Person of Significant Control (PSC) framework, often recording trustees as controllers instead of settlors or beneficiaries. Non-UK and UK non-resident trusts usually avoid registration with HMRC or the Trust Registration Service, except in limited cases. When layered with tools like PPLI, UK companies can even file as dormant, bypassing audits. In certain setups—such as non-resident trusts in CRS non-participating jurisdictions—no CRS reporting is required, adding further confidentiality.