Publications for Private Client Tax Committee

Home is where the heart is… or the taxman says! Global mobility and the digital nomad

prioritising stability, lifestyle and professional ecosystems over purely tax-driven relocation strategies.

Released on Apr 28, 2026

The $100,000 jurisdictional challenge: a fast-paced and exciting discussion comparing old and new planning jurisdictions

The private wealth landscape is increasingly shaped by multi-jurisdictional planning, as families seek to combine the advantages offered by different legal systems. The ‘$100,000 jurisdictional challenge’ session brought together practitioners from Guernsey, Malta, Singapore and Poland, with additional commentary on Panama, to compare the structuring tools, tax environments and practical realities in each jurisdiction.

Released on Apr 28, 2026

Drifting away and losing focus: the aging high-net-worth client in their wisdom, confusion and vulnerability

This conference session addressed one of the most sensitive and increasingly common challenges facing legal, tax and advisory professionals: how to respond when an ageing client becomes vulnerable, less autonomous and their decision-making is questioned, all this in the context of one’s mental capacity and exposure to undue influence. As global populations age and wealth concentrations grow among older individuals, professionals are encountering more cases where diminished capacity, undue influence and unconventional personal decisions converge.

Released on Apr 16, 2026

Murphy’s law in estate planning: things will and have gone wrong

This panel session explored real-life scenarios where detailed planning of succession and wealth-holding strategies have not gone to plan. Cross-border examples were used to highlight situations where such plans have shifted due to the interplay between different legal systems, family structures and human error. Rather than adopting a pessimistic tone, the session positioned Murphy’s law, the adage that ‘anything that can go wrong, will go wrong’, as a practical discipline that is relevant to estate planners advising global families with cross-border assets. Indeed, during cross-border planning, ‘anything that can go wrong, will go wrong’.

Released on Apr 16, 2026

Navigating civil law constructs in common law jurisdictions: why make it easy when complexity is an option?

Civil law estate planning tools, such as usufruct, bare ownership and fiduciary arrangements, are widely used across continental Europe. However, when these concepts are applied in common law jurisdictions, their legal characterisation and tax treatment can become uncertain. A recent panel session at the IBA Private Client Tax Conference in March 2026 explored these challenges, emphasising the importance of simplicity, coordination and clear structuring within cross-border planning.

Released on Apr 12, 2026

The four-pillar dialogue: family office, legal, banking and investment advisory

This session explored how geopolitical uncertainty, global mobility and regulatory change are reshaping the priorities of international families, from the rising demand for alternative residencies to the way sanctions and evolving tax policies influence cross‑border banking. Governance and succession emerged as central themes, with an emphasis on establishing flexible structures that clarify roles across both family and business spheres.

Released on Apr 12, 2026

International estate planning for Latin American families: Miami, Madrid or both?

This conference session examined the key legal and tax challenges involved in cross-border estate planning for families with connections to Colombia, Mexico, Brazil, Spain and the United States, focusing on the interaction between different matrimonial regimes, succession rules and inheritance taxation across multiple jurisdictions.

Released on Apr 12, 2026

New York’s new power of attorney law is a welcome change

Practitioners will no longer need to apologise to their estate planning clients regarding the form of power of attorney required throughout the State of New York. The statutory form has been reworked – in the author’s view, this follows years of frustration for attorneys and their clients alike.

Released on Aug 2, 2021

Israeli Tax Authority actively approaches Switzerland to obtain information

In July 2021, the Israeli Tax Authority requested information from the Swiss Federal Tax Administration on affluent Israelis and their families in connection with bank accounts and assets held by them in Switzerland, individually and through foreign companies.

Released on Aug 2, 2021

Planning for the US person moving to Europe

This panel at the IBA 2020 - Virtually Together conference discussed various income tax and estate/gift tax planning issues that arise when a person from the United States relocates to Europe. A case study was presented, for which each of the panellists provided commentary regarding the tax treatment in their various jurisdictions: France; Italy; Spain; Switzerland; and the UK respectively.

Art: private passion or private client asset? Report on a session at the IBA’s 25th International Private Client Conference

The panel addressed the multiple crossover legal issues and passions involved in the acquiring, holding and disposing of art.

The IRS global high wealth industry group: how the IRS targets high net worth individuals

In this article, we focus on the group specifically formed by the US Internal Revenue Service to audit high net worth individuals and how global transparency has impacted its activities.

UBO registers: the emerging monsters in our midst

The panel looked at the implementation of the Fifth EU Money Laundering Directive, its planned implementation in regard to the various beneficial ownership registers, and how both EU Member States and non-EU countries are developing their own approaches to the gathering of relevant information on ultimate beneficial owners.

Book review: Trusts in Prime Jurisdictions, 5th edition

A review of a two-volume book dealing with trusts, which has recently been updated. The editors of Trusts in Prime Jurisdictions have brought together more than 50 contributors, mostly from common law countries but also a few from civil law jurisdictions.

CJEU judgment C-80/19: national certificate of inheritance versus European Certificate of Succession

An article covering the judgment of the Court of Justice of the European Union (first chamber) of 16 July 2020 C-80/19.

Israel's international tax system for individuals – new rules?

Any person who is considered an Israeli tax resident is subject to tax in Israel with respect to their worldwide income. Therefore, any income produced or accrued by an Israeli tax resident from a source within Israel or abroad is subject to tax in Israel. At the same time, a foreign tax resident (ie, a person who is not an Israeli tax resident) is generally subject to tax in Israel only with respect to income that was derived from a source within Israel.

Is Malta the domicile of choice for crypto-millionaires?

Bitcoin has been around since 2009, gradually increasing in value over the years under most people’s radar. In a timespan of barely two years, however, the world witnessed the meteoric, rise and subsequent price correction of bitcoin and hundreds of other cryptocurrencies, altcoins and tokens.

The internationally mobile athlete: on pitch, on track, on image – advising professional sporting clients

This panel discussed the opportunities and challenges that are facing the internationally mobile athlete from the perspective of various jurisdictions.

I’m a beneficiary, get me out of here!

The panel addressed the challenges posed by modern families, but also new types of assets that can be part of international estates, such as digital assets and cryptocurrencies. The law of the administration of such international estates can be a jungle when taking into consideration modern family ties and concepts, as well as these new types of assets that can be treated differently (if at all) by various jurisdictions.

The planner’s liability – an expanding scope

In this session, the panel shared their personal experience with clients that have caused them great concern, including by concealing the true purpose of the advice they were seeking or coming from a high-risk jurisdiction or by not disclosing all the facts and circumstances that would be relevant to the planner to give proper advice.

Undisciplined clients: what to do when families make personal decisions that do not accord with their structure?

The main focus of this session was on undisciplined clients, the impact of their choices and the changing circumstances in their lives on estate planning, and how to anticipate this in our advisory practices. During this session, the panel thoroughly discussed what the specific role and goal of a private client adviser is when being confronted with clients who live their lives with little or no regard for the legal consequences of their actions on their estate planning.

Navigating Mexico’s 2020 tax reform in the context of US investments for high net worth individuals

In this article, the authors discuss the myriad of changes to Mexico‘s entity classification rules and controlled foreign corporate (CFC) regime. Such changes potentially affect Mexican resident individuals that have elected to use offshore limited partnerships to conduct their investments in ‘US situs assets’. Mexican resident individuals investing through these vehicles may face different income tax rates, different income characterisations and disclosure requirements.