Private Wealth Newsletter - Second Quarter 2021

Welcome to the Second Quarter 2021 issue of the Private Wealth Newsletter. In this edition, we feature an article addressing the growing concern of many high net worth (HNW) individuals regarding a current “tax the rich” trend among various countries. Given that many HNW individuals are increasingly mobile, our feature article reviews alternative personal tax systems commonly referred to as “res non dom” and “lump-sum tax” in the UK, Italy and Switzerland. We also continue the theme around the globe covering developing highlights impacting HNW individuals from the UK, France, Spain, China, Taiwan, Cayman, Brazil, the US and Canada. And finally, as part of our consistent tracking around the globe, we present updates by region from APAC, Americas, and EMEA.

Feature: Overview of alternative personal taxation regimes in the United Kingdom, Italy and Switzerland

Issue Highlights:

• New criterion on the calculation of the inheritance tax in Spain
• Cayman court decision removes sting in the tail of firewall legislation (re Stingray Trust)
• FCPA: US v. Ho
• United Kingdom Freeports
• Expansion of mandatory disclosure rules proposed in Budget 2021
• Sale of Brazilian real estate assets by a French resident
• Impact of Brexit on French social surtaxes
• Transfer of assets through a trust
• Strengthening tax compliance of HNWIs
• Two cases relating to the determination of the PRC tax residency status of individuals
• Intestacy and inheritance rights of same-sex spouses
• The Taiwan CFC rules are around the corner