Insights
Notes from the practice
Commentary on cross-border structuring, banking, residence, tax and regulatory change. Articles more than 24 months old carry a note saying so.
All articles
598 articles, page 4 of 13
Tax Strategy
Smart Tax Strategies for HNW Individuals: Planning Beyond Compliance
Filing tax returns is compliance. Planning is the year-round structuring of income, assets and succession within the reliefs and timing rules the law provides, with each position documented. For wealthy individuals, the difference can be material.
Corporate
How to Choose a Holding Company Jurisdiction
A practical guide to choosing a holding company jurisdiction: treaty access, participation exemptions, substance, withholding tax and exit planning.
Structures
Royalty Streaming Through Offshore Structures Explained
How royalty streaming offshore structures work for IP income, why nexus and substance rules reshaped them, and how to build a defensible arrangement.
Structures
Intellectual Property Holding Structures: A Guide
A practical guide to intellectual property holding structures: choosing a jurisdiction, nexus and substance rules, IP boxes, and avoiding common mistakes.
Corporate
Offshore Joint Venture Structures: A Practical Guide
How offshore joint venture structures work: choosing a vehicle and jurisdiction, governance, deadlock and exit, tax and substance, and common pitfalls.
Asset Protection
Cook Islands Trust: The Complete Asset-Protection Guide
A clear-eyed guide to the Cook Islands trust, the world's leading asset-protection vehicle, its statutory strengths, real limits, and legitimate use.
Corporate
Special Purpose Entities: A Practical Guide for HNW Structures
A clear guide to special purpose entities (SPEs): what they are, how they are structured, the legal and tax pitfalls, and when an SPE actually adds value.
Structures
Offshore Real Estate Structures: A Strategic Guide
How offshore real estate structures actually work: holding companies, trusts, tax exposure in the property's country, succession, privacy and the real pitfalls.
Structures
Liechtenstein Anstalt and Foundation: A Practical Guide
A clear guide to the Liechtenstein Anstalt and foundation: how each works, their tax and substance position, asset protection, succession and modern.
Corporate
Company Redomiciliation: Migrating an Entity Cross-Border
A practical guide to company redomiciliation: how migrating an entity between jurisdictions works, the tax and continuity issues, and when it beats.
Corporate
Company Dissolution: The Tax Implications You Cannot Ignore
Company dissolution carries tax implications that surface long after closure. We explain capital, income, and cross-border exposure before you wind down.
Funds
The Cayman Master-Feeder Fund Structure Explained
How the Cayman master-feeder hedge fund structure works, why it exists, the role of onshore and offshore feeders, and the substance it now requires.
Corporate
Shelf Company vs New Incorporation: Which Is Right?
A shelf company promises instant history; a new incorporation offers a clean slate. We compare the two honestly, including the aged-company credit myths.
Compliance
Offshore Company Annual Compliance Checklist for 2026
An offshore company annual compliance checklist covering registry filings, economic substance, beneficial ownership, and accounting records for 2026.
Compliance
Offshore Company Annual Compliance: What 2026 Requires
Offshore company annual compliance in 2026 means substance, beneficial ownership, accounts, and information exchange. We explain what good standing now takes.
Banking
Offshore Company Banking: Enhanced Due Diligence Explained
Enhanced due diligence is the gatekeeper for offshore company banking. We explain what banks ask, why, and how to prepare a file that opens accounts.
Banking
Offshore Company Banking Guide: What Works in 2026
A 2026 guide to offshore company banking: where accounts actually open, how onboarding has changed, and how to bank an offshore entity without surprises.
Mobility
Dominica Citizenship by Investment: A Practical Guide
A clear guide to Dominica citizenship by investment, comparing the donation and real-estate routes, due diligence, passport utility and who it suits.
Regulatory
CRS Expansion 2025: New Jurisdictions and Crypto
The Common Reporting Standard keeps expanding into new jurisdictions and crypto assets. Here is what automatic exchange means and why transparency wins.
Regulatory
Beneficial Ownership Registers: What Changed in 2025
Beneficial ownership registers reshaped corporate transparency in 2025. We explain who must file, who can see it, and what owners should do now.
Regulatory
Beneficial Ownership Registers Worldwide: A Country Guide
A worldwide guide to beneficial ownership registers: how the rules differ by region, who can access the data, and what it means for international structures.
Compliance
Nominee Director and Shareholder Risks: What to Know
Nominee director and shareholder arrangements carry real legal and tax risks. We explain where they fail, where they still work, and how to use them safely.
Compliance
Nominee Director Risks: A Practical Guide
A practical guide to nominee director risks: personal liability, loss of control, tax-residence traps, and how to use nominee directors safely and compliantly.
Asset Protection
Why Cook Islands Asset Protection Is the Gold Standard
Cook Islands asset protection is widely regarded as the gold standard for entrepreneurs. We explain why the regime is so robust, and where its real limits lie.
Compliance
Economic Substance Rules for Offshore Companies
Economic substance rules now apply across offshore jurisdictions. Here are the relevant activities, the substance test, penalties, and real substance.
Asset Protection
Cook Islands Trust Asset Protection: A Complete Guide
A complete guide to the Cook Islands trust for asset protection: how it works, the statutory shield, tax and reporting reality, costs, and who it suits.
Tax Strategy
CFC Rules: The Hidden Force Shaping Offshore Structures
Controlled Foreign Corporation rules allow high-tax countries to tax residents on the undistributed income of foreign companies they control. Understanding how the UK, US, Germany and Netherlands apply these anti-deferral provisions is essential for anyone structuring international entities.
Structures
Cayman STAR Trusts: A Guide to Purpose Trusts
How a Cayman STAR trust works as a purpose trust for holding companies, philanthropy and dynastic wealth, with the role of the enforcer explained.
Structures
Panama Private Interest Foundation: A Complete Guide
How a Panama private interest foundation works for estate planning and asset protection, including founders, council, beneficiaries, tax and pitfalls.
Structures
Jersey Trust Law: A Guide for International Families
A practical guide to Jersey trust law for international families, covering reserved powers, firewall provisions, the trustee's duties, tax and pitfalls.
Structures
Guernsey Foundation: A Guide to the Structure
How a Guernsey foundation works, covering councillors, guardians, beneficiaries, the disenfranchised, tax treatment, substance and common pitfalls.
Structures
Dynasty Trusts: Multi-Generational Wealth Planning
A dynasty trust can hold and protect family wealth across generations. We explain how these structures work, where they sit, and the pitfalls to avoid.
Structures
Charitable Trusts for Offshore Philanthropy
An offshore charitable trust can structure giving across borders with permanence and governance. We explain how charitable trusts work and what to watch for.
Asset Protection
Spendthrift Trusts and Creditor Protection
A spendthrift trust can shield a beneficiary's inheritance from creditors and poor judgement. We explain how spendthrift protection works and its real limits.
Compliance
Offshore Trust US Reporting Obligations Explained
US persons with offshore trusts face strict IRS reporting. We explain the key filings, who must report, and the penalties for getting it wrong.
Structures
The Trust Protector: Role, Powers and Pitfalls
A clear guide to the trust protector role: what protectors do, what powers they hold, the fiduciary risks, and how to appoint one without weakening the trust.
Structures
Foundation vs Trust: Which Wealth Structure Is Right?
A practical foundation vs trust comparison for international families: how each works, their legal and tax differences, and how to choose between them.
Mobility
Vanuatu Citizenship: Speed, Trade-offs and Reality
An honest guide to Vanuatu citizenship by investment: the speed of the process, the real trade-offs, and how it compares with Caribbean options.
Structures
Private Trust Company Establishment: A Family Guide
How private trust company establishment works for wealthy families: when a PTC makes sense, the structure, governance, regulation, and the practical pitfalls.
Asset Protection
Asset Protection Trust Timing: Why Acting Early Matters
Asset protection trust timing is decisive. Why setting up a trust before a claim arises makes it work, and the fraudulent transfer risks of waiting.
Structures
Offshore Life Insurance Wrappers: A Planning Guide
How an offshore life insurance wrapper can defer tax, simplify succession and consolidate a global portfolio for high-net-worth families.
Structures
Private Placement Life Insurance: A Complete Guide
Private placement life insurance (PPLI) lets qualified investors hold alternatives tax-efficiently inside an insurance wrapper. How PPLI works and its rules.
Structures
Trust Deed Contents: What the Document Must Cover
A clear guide to trust deed contents: the essential clauses, powers and protections every well-drafted offshore trust deed should address.
Asset Protection
Settlor Retained Powers and the Sham Trust Risk
How much control can a settlor keep before a trust is attacked as a sham? A practical guide to settlor retained powers and sham trust risk.
Structures
Offshore Annuities in Estate Planning: A Practical Guide
How offshore annuities work in estate planning, where they add value, the reporting they trigger, and the pitfalls to avoid for international families.
Structures
Forced Heirship and Offshore Trusts: Planning Guide
How forced heirship rules affect cross-border estates and how offshore trusts can help, with the firewall protections, limits, and pitfalls explained.
Compliance
Offshore Trust Disclosure: CRS and FATCA Explained
What CRS and FATCA require offshore trusts to report, who is classified how, and how to stay compliant. A clear guide to offshore trust disclosure.
Structures
The Strategic Power of Offshore Trusts for Wealth
How offshore trusts secure wealth, legacy, and legitimate confidentiality for international families, with the real benefits and limits explained.
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Reference
Guides and comparisons
Longer guides on jurisdictions, structures and routes to residence.
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Example scenarios
Illustrative scenarios showing how a matter is approached.
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Glossary
Plain-English definitions of cross-border terms, from ATED to VASP.
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Questions clients ask
How the firm works, what it charges and where it operates.
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Much of the firm's thinking sits in client memoranda rather than published articles. The note covers the parts that apply more widely: changes in jurisdictions, banking practice and regulatory deadlines.
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