On behalf of Baker McKenzie's Global Wealth Management Practice Group, it is our pleasure to share with our clients, friends, colleagues and readers across the globe the 2023 final edition of the Private Wealth Newsletter.
In this edition, we present the second instalment of our video interview series, showcasing our team members across offices. Juan David Velasco, a Partner in our Bogota office, discusses his experience with the Firm and the challenges facing clients, including privacy concerns as the wealthy come under increased scrutiny.
This edition focuses on the taxes applicable to globally mobile ultra-wealthy individuals and the tools available to governments to effectively tax cross-border wealth. Our featured article by Phyllis Townsend and Oliver Stephens considers the recent proposal by the EU Tax Observatory for a global wealth tax and the reasons this is unlikely to be implemented. Inconsistencies still exist including between jurisdictions that have signed up to existing global initiatives and even within jurisdictions. Juan David Velasco and Sofía Rodríguez consider the disparity between the rule for determining the tax base of income tax and the wealth tax on foreign investment vehicles in Colombia.
Lily Kang and Mathieu Wiener highlight the potential for US tax liability to arise for non-US citizens under the lesser known substantial presence test which serves as a useful reminder for those spending time in the US.
The “Around the World” section includes an update on the decision of the Spanish Constitutional Court to uphold the solidarity tax on large fortunes, and other updates from our colleagues globally.
We wish you all the best for the holiday season and 2024.
Issue highlights:
A global minimum tax rate for the ultra wealthy: likely any time soon?
Disparity between the rule for determining the tax base of income tax and wealth tax on foreign investment vehicles
Beyond presence: exploring the substantial presence test and its exceptions
Around the world
PWN meets...
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