Two measures received Royal Assent in June 2026 and between them displace assumptions that have underpinned Australian structuring for twenty-five years. The general 50% capital gains discount for individuals, trusts and partnerships is replaced from 1 July 2027 with cost base indexation and a 30% minimum tax rate on capital gains, applying only to gains […]
Advisers approaching an Indonesian file from a common law background encounter the same difficulty in each case. The instruments the practice relies on, the discretionary settlement and the fiduciary relationship behind it, have no counterpart in Indonesian law, cannot be pleaded before an Indonesian court, and interact awkwardly with a succession regime that is both […]
Practitioners advising on private placement life insurance for a UK-connected client will be familiar with the difficulty: the product as constituted in the United States, a bespoke contract over a separately managed account with the policyholder’s own manager selecting the assets, is the paradigm case at which the personal portfolio bond legislation is directed. What […]
On 24 July 2026 the Ministry of Finance and the State Taxation Administration issued Announcement No. 21 of 2026, Announcement Regarding Individual Income Tax Matters for Offshore Trusts, together with STA Announcement No. 15. Both took effect on publication. For the first time, China has a defined individual income tax regime for offshore trusts holding […]
The HK SFO exemption covers securities management for a single family but does not extend to insurance placement — meaning PPLI must be placed by a licensed broker. This article examines how the SFO framework and PPLI interact, and what family office advisors need to structure correctly.
The PPLI domicile determines regulatory protections, asset flexibility, treaty access, and counterparty infrastructure. This article compares Luxembourg, Liechtenstein, Cayman Islands, and Barbados across the criteria that matter most for international structuring.
PPLI for US persons must satisfy IRC Section 7702, the Investor Control Doctrine, and IDF requirements to preserve tax deferral and eliminate PFIC exposure. This article explains the three compliance pillars that advisors must understand before recommending PPLI to any US-connected client.
The avance sur police allows PPLI policyholders to access liquidity directly from the insurer against the policy surrender value — without a bank, without a taxable event, and without disrupting the policy’s investment mandate. This article explains the mechanics and corrects a common market misconception.
The tax efficiency of PPLI is maximised before the policyholder becomes tax-resident in the destination jurisdiction. This article examines the pre-immigration planning window for the US, Australia, Spain, and Hong Kong, and the critical timing thresholds beyond which the benefit is materially compromised.
PPLI can accommodate direct cryptocurrency contributions via wallet-to-policy transfer without fiat liquidation. This article sets out the mechanics, structural requirements, carrier considerations, and jurisdiction-specific tax analysis including PRC-resident implications.
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Aug 18, 2026 





