International tax planning, estate and inheritance tax, real estate taxation, and trust tax structures for complex wealth situations that cross borders and generations.
46 articles
Liechtenstein wealth is not an accident of geography or a relic of royal privilege. This 160-square-kilometer principality between Switzerland and Austria has built one of the highest GDP per capita figures on earth, consistently exceeding $180,000 USD according to World Bank data, several multiples
Portugal does not have a broad net wealth tax. What it has is the Adicional Imposto Municipal sobre Imóveis (AIMI), introduced in 2017, which targets high-value real estate specifically. If you own Portuguese property with a combined taxable value above €600,000, you pay AIMI annually. Financial ass
The Spain wealth tax calculator question most high-net-worth individuals ask first is deceptively simple: do I even owe this? The answer depends on residency status, asset location, and which of Spain's 17 autonomous communities you call home. Residents pay on worldwide assets. Non-residents pay onl
The Netherlands wealth tax operates through a deemed-return system called Box 3, which taxes an assumed yield on your net investment assets rather than actual gains or income. For a Dutch tax resident holding a €10 million investment portfolio, the 2023 effective rate of roughly 1.97% on gross asset
Albany has introduced legislation that would impose an annual tax on net worth, not income, for New York residents holding significant accumulated assets. The most recent version, S.2162 / A.3252 (the New York State Ultra-Millionaire Tax Act), proposes rates up to 1% on net worth exceeding $1 billio
Argentina's Extraordinary Solidarity Contribution (Aporte Solidario y Extraordinario), enacted as Law 27.605 in December 2020, is a one-time levy on individuals with global assets exceeding 200 million Argentine pesos. At the official exchange rate, that threshold translated to roughly $2.5 million
The Maryland wealth tax proposal would levy an annual tax on total net worth, not income, targeting residents above a specific asset threshold. Early legislative discussions center on a $1 billion floor, with rates ranging from 1% to 3%. But if you hold $5M to $50M in illiquid assets, the structural
Hungary's capital gains tax rate sits at a flat 15%, applied through the personal income tax system with no separate CGT category. For property held more than five years, the tax drops to zero. For investors running capital through a Hungarian holding company, qualifying share disposals can exit com
If you have $5M or more in investable assets, the question isn't whether you need a director of wealth management. It's whether the one you have (or are considering) is actually earning their fee. At this level, the difference between a skilled wealth director and a generalist advisor isn't measured
Under IRC Section 121, single filers can exclude up to $250,000 in home sale gains from federal tax; married couples filing jointly can exclude up to $500,000. If your primary residence has appreciated well beyond those thresholds, the planning decisions you make before listing will determine whethe
Cross border tax planning is the discipline of structuring international income, assets, and business operations across multiple jurisdictions to reduce total tax liability while remaining compliant with every country's rules. For individuals with $5M+ in assets, this is not optional sophistication.
Non-resident capital gains tax treatment in the U.S. turns almost entirely on one threshold question: does the IRS classify you as a non-resident alien (NRA)? The answer determines which assets get taxed, at what rate, and through what withholding mechanism.
Israel's capital gains tax system looks straightforward on paper: 25% for individuals, 30% for substantial shareholders. In practice, a 3% surtax on high earners, a separate real estate regime, and an aging U.S. treaty full of planning gaps mean your effective rate can land well above the headline f
Each tenant in common pays capital gains tax on their proportionate share of the gain, calculated independently, reported on their own return. That individual treatment creates real planning opportunities, but it also means your co-owner's tax situation is completely irrelevant to yours. For high-ne
The Cayman Islands imposes zero capital gains tax. No income tax, no corporate tax, no inheritance tax. For non-US investors who can genuinely establish residency there, that zero is real and material. For US citizens, it is largely irrelevant, and that distinction is the most important thing this
Most buyers closing on a $5M Manhattan apartment assume the mansion tax works like a property tax: painful, but at least partially deductible. It doesn't. The IRS treats most mansion taxes as transfer taxes, which means they get capitalized into your cost basis under IRC Section 1012, not deducted i
Sell a $3M investment property in California without planning, and you could write a check to the government for over $900,000. That's not a hypothetical scare tactic. It's the math when you stack a 20% federal long-term rate, 3.8% Net Investment Income Tax, 25% depreciation recapture, and Californi
International tax planning in Singapore starts with a 17% headline corporate rate, zero capital gains tax, no inheritance tax, and a network of over 90 double taxation agreements. For non-US passport holders especially, the structure is genuinely compelling. But the gap between the rate sheet and a
Italy's inheritance tax is, by international standards, remarkably light. The Agenzia delle Entrate applies rates of 4%, 6%, or 8% depending on your relationship to the deceased, with a €1 million per-heir exemption for spouses and direct descendants. For a reader with a €10 million Italian property
Most of your monthly co-op maintenance fee is not deductible. The portion that is comes down to two pass-through items: your allocable share of the building's real estate taxes and your allocable share of the underlying mortgage interest. Under IRC Section 216, those two components qualify for itemi
Yes. If you own UK property or land as a non-resident, HMRC will tax your gains. UK capital gains tax for non-residents applies to residential property since April 2015, commercial property and indirect disposals since April 2019, and the rules have tightened every year since. Understanding exactly
California residents who inherit assets from abroad owe no state inheritance tax and typically no federal income tax on the inheritance itself. That sounds clean. It isn't. The real exposure on foreign inheritance tax in California comes from federal reporting obligations, ongoing income taxation of
Real estate commissions and tax deductions follow a specific mechanic that most sellers misunderstand: commissions don't create a direct deduction. They reduce your "amount realized" on the sale, which shrinks your taxable gain. For sellers in high-cost markets with appreciation well above the §121
Norway's capital gains tax rate is 22% flat for both individuals and corporations. That headline number is accurate and also incomplete. For share investors, the shareholder model (aksjonærmodellen) applies an upward adjustment factor of 1.72 to gains above the shield deduction, pushing the effectiv
Refinancing does not trigger capital gains tax. The IRS confirms in Publication 544 that refinancing a mortgage does not constitute a taxable disposition of property. Loan proceeds are debt, not income, which means a cash-out refinance is one of the few ways high-net-worth real estate investors can
Greece taxes capital gains at a flat 15% rate. That headline figure is straightforward. What isn't straightforward is the web of exemptions, calculation rules, Non-Dom regime implications, and cross-border complications that determine what you actually owe after selling a Greek property or unwinding
South Korea's capital gains tax system is one of the most rate-variable in the OECD, with effective rates on real estate ranging from near zero to over 70% depending on holding period, property count, and zone classification. If you hold Korean assets above the KRW 1 billion threshold, the differenc
Singapore's 17% headline corporate tax rate is already competitive. But for high-net-worth individuals and business owners who understand the full structure, the effective rate can drop substantially lower through entirely legal means. The distinction that matters is not between "aggressive" and "co
The short answer: probably not at the federal level, and almost certainly less than you think. The federal estate tax exemption for 2024 sits at $13.61 million per individual, which means most FATFIRE estates currently clear it cleanly. But "currently" is doing a lot of work in that sentence. The TC
Inheritance tax in South Africa is called estate duty. It applies at 20% on dutiable estates up to R30 million and 25% on amounts above that threshold, with a primary abatement of R3.5 million per deceased estate. For anyone holding R30M+ in assets, the exposure is real and the planning window matte
The 5-year rule for trusts is one of several distribution timelines governing inherited retirement accounts, and it matters far more now than it did five years ago. SECURE Act 2.0, effective January 1, 2023, eliminated the stretch IRA for most non-spouse beneficiaries, compressing what was once a li
S corp stock gifting to family members is one of the most effective estate planning moves available to business owners with concentrated private equity positions, but the IRS has built several traps into the rules that retail-level advice consistently ignores. The core tension: gifting transfers own
The irrevocable trust home sale exclusion is one of the most misunderstood intersections in estate planning. The conventional framing, that you can combine these two tools for maximum benefit, gets the mechanics backwards. For most people with $5M+ estates and heavily appreciated homes, placing a
The irrevocable trust 5-year rule is a Medicaid lookback provision, not an estate planning deadline. Federal law under 42 U.S.C. § 1396p requires Medicaid to review asset transfers made within 60 months of an application for long-term care benefits. Transfers into an irrevocable trust during that wi
Yes, beneficiary contributions to irrevocable trusts are legally possible, but the tax and structural consequences are serious enough that most attorneys treat this as a last resort rather than a default move. The 2025 estate tax exemption sunset makes the timing of any such contribution more conseq
Swiss inheritance law for non-residents is not a minor administrative detail. If you hold Swiss real estate, a Swiss bank account, or an interest in a Swiss operating company, Swiss succession rules will govern how those assets transfer at death, regardless of what your home-country will says. The 2
Inheritance attorney fees for large estates typically run $5,000 to $15,000 for straightforward planning engagements, $25,000 to $75,000 for complex trust structures, and well over $150,000 when probate litigation enters the picture. For FATFIRE-level estates, the more important question is not how
Belgium inheritance tax ("successierechten" in Dutch, "droits de succession" in French) can consume 27% to 80% of an estate depending on region, heir relationship, and asset type. For a €10M estate, the difference between a well-structured plan and no plan at all can exceed seven figures in tax liab
Cyprus has zero inheritance tax. Full stop. Under the Estate Duty (Amending) Law of 2000, the Republic of Cyprus eliminated all estate and inheritance duties, making it one of the few EU jurisdictions where assets transfer at death without triggering a tax charge. For high-net-worth individuals eval
The short answer: generally no, but the exception matters more than the rule. State inheritance taxes are typically paid by beneficiaries, not the estate, which puts them outside the deductible expenses on Form 1041. However, when the governing instrument directs the estate to pay those taxes, deduc
Ownership of inheritance determines your tax liability, creditor exposure, and control rights from the moment assets transfer. For estates above $5 million, the structure of that ownership can mean the difference between a clean transfer and a forced asset sale to cover a tax bill. The mechanics are
The Section 645 election for irrevocable trusts is one of the most time-sensitive and underused post-mortem tax elections available to estate administrators. It allows a qualified revocable trust (QRT) to be treated as part of the decedent's estate for income tax purposes during the administration p
British inheritance law hits differently when your estate clears £2 million. The standard retail advice, "write a will, maybe set up a trust", was written for people with a house and a pension. If you're sitting on a £5M+ estate, the arithmetic is brutal: a couple with £6 million and no planning f
A limited power of appointment irrevocable trust combines the asset protection and estate tax benefits of an irrevocable structure with a built-in mechanism for post-transfer flexibility. The power holder can redirect trust assets among a defined class of beneficiaries without triggering estate tax
Denmark still levies inheritance tax. The boafgift remains fully in force as of 2024, and anyone telling you Denmark abolished it is wrong. The rate is 15% for close relatives on amounts above the annual exemption, with an effective rate of 36.25% for more distant heirs. If you hold Danish assets or
IRC §179(d)(4) says no, at least not directly. Trusts and estates are explicitly barred from claiming Section 179 deductions at the trust level. That is the threshold rule, and most articles stop there. The more useful answer is that the prohibition is entity-level, not absolute. Grantor trusts, bus