Australia After the 2026 Reforms: Wrapper Analysis for Trustees and Advisers

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 […]

Indonesia: Structuring Where the Trust Is Not Recognised

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 […]

Offshore Policies After the Non-Dom Reforms: A Note for Trustees and Advisers

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 […]

Announcement No. 21 and Private Placement Life Insurance: Reading the Carve-Out

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 […]