Offshore Tax with HTJ.tax
Episodes
US Social Security and Moving to France
11 Mar 2026
Contributed by Lukas
Relocating to France can affect not only your tax residency but also how retirement income—such as U.S. Social Security—is taxed. In this episode,...
Taxing Online Business Income in France
10 Mar 2026
Contributed by Lukas
Running an online business from France—whether consulting, freelancing, or selling digital products—doesn’t mean the income escapes French taxat...
How France Taxes Foreign Life Insurance
09 Mar 2026
Contributed by Lukas
Foreign life insurance policies can be highly efficient wealth planning tools—but once you become a French tax resident, they are subject to specifi...
US Estate Plans After Moving to France
08 Mar 2026
Contributed by Lukas
Relocating to France does not automatically invalidate your existing U.S. estate plan—but it can significantly affect how that plan operates. In thi...
What Happens to My Estate If I Die in France?
07 Mar 2026
Contributed by Lukas
If you live in France—or have lived there long enough—your estate may fall within the French inheritance tax system. In this episode, we explain h...
Inheriting Assets as a French Resident
06 Mar 2026
Contributed by Lukas
Becoming a French tax resident can significantly change how inheritances are taxed—especially when assets or family members are located abroad. In t...
Are US Charitable Donations Deductible in France?
05 Mar 2026
Contributed by Lukas
Charitable giving can become surprisingly complex when you move across borders. A donation that is fully deductible in the United States may not produ...
Gifting from France to the US: Who Taxes It?
04 Mar 2026
Contributed by Lukas
Cross-border family gifts often trigger confusion—especially between France and the United States. In this episode, we clarify who taxes what, how t...
How France Taxes US Dividends and Capital Gains
03 Mar 2026
Contributed by Lukas
If you are a French tax resident holding U.S. investments, your returns are not just subject to U.S. tax rules—they fall squarely within the French ...
Timing of US Deferred Compensation After Moving to France
02 Mar 2026
Contributed by Lukas
When U.S. deferred compensation is paid after you become a French tax resident, timing becomes critical. The interaction between U.S. taxation and Fre...
Avoiding Double Tax Between the US and France
01 Mar 2026
Contributed by Lukas
When income is taxed in both the United States and France, the solution is not exemption—it’s coordination. In this episode, we explain how the fo...
US 409A Deferred Compensation & French Tax Residency
28 Feb 2026
Contributed by Lukas
Cross-border executives often assume deferred compensation is taxed where it was earned. Under U.S. Section 409A, that assumption can be costly once y...
Moving Funds Out of China - Privately
27 Feb 2026
Contributed by Lukas
China’s 2018 ODI reforms (Order No. 11) strengthened supervision of outbound investments. In this episode, we clarify what investors must do before,...
China’s Restricted ODI Investments
26 Feb 2026
Contributed by Lukas
China’s Outbound Direct Investment (ODI) regime does not only classify projects as “encouraged” or “prohibited.” A significant middle catego...
China’s Prohibited ODI Investments
25 Feb 2026
Contributed by Lukas
While China encourages strategic outbound investment, certain categories are strictly prohibited. Projects that threaten national interests or nationa...
ODI Projects the Government Supports
24 Feb 2026
Contributed by Lukas
China’s Outbound Direct Investment (ODI) policy is not neutral—it is strategically guided. Certain categories of overseas investment are actively ...
China’s 2018 ODI Rule Changes
23 Feb 2026
Contributed by Lukas
In March 2018, China introduced significant reforms to its Outbound Direct Investment (ODI) regime. These changes—implemented through Order No. 11—...
China’s Outbound Investment Rules
22 Feb 2026
Contributed by Lukas
China’s Outbound Direct Investment (ODI) regime has evolved from strict pre-approval controls to a more structured, risk-based regulatory system. In...
ODI and Wealth Management Opportunities
21 Feb 2026
Contributed by Lukas
China’s Outward Direct Investment (ODI) regime channels substantial capital abroad each year. For global wealth managers, trustees, funds, and priva...
What Is China’s ODI Initiative?
20 Feb 2026
Contributed by Lukas
China’s Outward Direct Investment (ODI) strategy operates on two parallel tracks: large-scale state-backed projects under the Belt and Road Initiati...
Hong Kong vs Switzerland: Look-Through Rules for Trust Equity Interests
19 Feb 2026
Contributed by Lukas
This episode explores how different jurisdictions interpret the CRS look-through rules for trusts that qualify as Reporting Financial Institutions (FI...
OECD CRS FAQ On Equity Interest Of A Financial Institution Held By A Financial Institution
18 Feb 2026
Contributed by Lukas
This episode looks at an often-cited but rarely analysed source: the OECD CRS FAQ on General Reporting Requirements, specifically Page 2, Question 7, ...
CRS Commentary on Financial Institutions Holding Equity Interests
17 Feb 2026
Contributed by Lukas
This episode examines a pivotal provision in the CRS Commentary—paragraph 178 (Section VIII, C(4))—and its implications for trusts that qualify as...
CRS Treatment of Financial Institutions as Equity Interest Holders
16 Feb 2026
Contributed by Lukas
This episode examines a core structural rule of the Common Reporting Standard (CRS): Financial Institutions are non-reportable persons and must not be...
Where Switzerland Misinterpreted the CRS Implementation Handbook
15 Feb 2026
Contributed by Lukas
This episode examines a narrow but consequential interpretative issue: Did Switzerland extend the CRS look-through rules for FI-trusts beyond what the...
The Core CRS / FATCA Principle: No Look-Through of Financial Institutions
14 Feb 2026
Contributed by Lukas
The Core CRS / FATCA Principle: No Look-Through of Financial InstitutionsAt the heart of both CRS and FATCA lies a fundamental architectural rule: Fin...
How Switzerland Misapplied CRS Look-Through Rules for Trusts
13 Feb 2026
Contributed by Lukas
In this episode, we examine a controversial development in Swiss CRS practice: the extension of look-through obligations for trusts that qualify as Re...
Who Is An Equity Interest Holder Of A Trust Qualifying As A Reporting FI
12 Feb 2026
Contributed by Lukas
Understanding who counts as an equity interest holder is central to how the Common Reporting Standard (CRS) operates for trusts that qualify as Report...
When Absence Doesn’t Break Residency
11 Feb 2026
Contributed by Lukas
Leaving a country does not automatically mean you stop being a tax resident. In this episode, we explain why tax residency is a legal status, not a tr...
Advice for Tax Advisors Going Forward
10 Feb 2026
Contributed by Lukas
As global tax enforcement intensifies and private wealth comes under greater scrutiny, the role of the tax advisor is evolving fast. In this episode, ...
Advising High-Net-Worth Individuals
09 Feb 2026
Contributed by Lukas
As global tax policy shifts toward greater scrutiny of private wealth, advising high-net-worth individuals with international assets requires a fundam...
The Future of Taxation's Pillar Three
08 Feb 2026
Contributed by Lukas
Beyond Pillar One and Pillar Two, a new concept is beginning to surface in global tax policy discussions: an informal “Pillar Three”—focused not...
The Expanding Definition of Private Income
07 Feb 2026
Contributed by Lukas
Digital nomads once thrived in the gaps between tax systems. Built around physical presence and permanent residence, traditional tax rules struggled t...
The Expanding Definition of Private Income
06 Feb 2026
Contributed by Lukas
Tax authorities around the world are quietly—but decisively—redefining what counts as private income. In this episode, we explore how governments ...
Wealth or Gift Taxes on Real Estate
05 Feb 2026
Contributed by Lukas
Real estate is increasingly at the center of wealth and gift taxation debates—and the implications reach far beyond tax rates alone. In this episode...
The Return of Wealth Taxes
04 Feb 2026
Contributed by Lukas
After decades of retreat, wealth taxes are making a comeback. Once common across advanced economies, net wealth taxes nearly disappeared by 2020—sur...
The Global Shift Toward Private Wealth Taxation
03 Feb 2026
Contributed by Lukas
A profound shift is underway in global fiscal policy. After decades of declining emphasis on wealth taxes, governments are renewing and intensifying t...
Pillar One and Pillar Two Explained
02 Feb 2026
Contributed by Lukas
The OECD’s Pillar One and Pillar Two reforms represent the most significant overhaul of international corporate taxation in decades. In this episode...
What Is The Main Risk In Cross-Border Gift Planning?
01 Feb 2026
Contributed by Lukas
In cross-border gift planning, the biggest mistakes rarely come from complex law—they come from misalignment. In this episode, we explain why the mo...
Can The Same Gift Be Taxed In More Than One Country?
31 Jan 2026
Contributed by Lukas
Yes—and this is one of the most common (and misunderstood) risks in cross-border gifting. In this episode, we explain how and why double taxation ca...
French Gift Tax Rules For Donations Manuelles
30 Jan 2026
Contributed by Lukas
Not all gifts are created equal under French law. In this episode, we explain how informal or manual gifts—called donations manuelles—are treated ...
What Happens In France When Both Donor And Donee Are Non-Residents?
29 Jan 2026
Contributed by Lukas
When neither the donor nor the recipient is fiscally domiciled in France, French gift tax applies on a strictly territorial basis. In this episode, we...
When Does French Gift Tax Apply To Gifts From Residents To Non-Residents?
28 Jan 2026
Contributed by Lukas
French gift tax rules change depending on who is resident and where the asset is located. In this episode, we explain when France taxes gifts made by ...
Are Gifts From Non-Residents Taxable When The Recipient Is French Resident?
27 Jan 2026
Contributed by Lukas
Yes—and this often catches families by surprise. In this episode, we explain why France can tax a gift on a worldwide basis even when the donor live...
Does France Tax Gifts On A Worldwide Basis?
26 Jan 2026
Contributed by Lukas
France takes a markedly different approach to gift taxation compared with many other countries. In this episode, we explain when France taxes gifts on...
What Happens In Portugal When Both Donor And Donee Are Non-Residents?
25 Jan 2026
Contributed by Lukas
A common misconception is that Portugal only taxes gifts when one of the parties lives there. In this episode, we explain what actually matters when b...
Is Stamp Duty Due When A Portuguese Resident Gives A Gift To A Non-Resident?
24 Jan 2026
Contributed by Lukas
When a Portuguese resident makes a gift to someone living abroad, a common question arises: does Portugal charge Stamp Duty because the donor is resid...
When Does Stamp Duty Apply To Gifts From Non-Residents In Portugal?
23 Jan 2026
Contributed by Lukas
Gifts involving non-residents often raise a key question: does Portugal tax the gift because the recipient lives there? In this episode, we clarify wh...
Are Family Gifts Always Reportable In Portugal?
22 Jan 2026
Contributed by Lukas
Family gifts in Portugal are often tax-free—but are they always reportable? In this episode, we explain the important clarification introduced by Po...
Are Gifts Between Close Family Members Taxed In Portugal?
21 Jan 2026
Contributed by Lukas
Portugal’s approach to family gifts is often misunderstood. In this episode, we explain when gifts between family members are completely tax-free—...
Who Is Taxed On A Gift In Portugal?
20 Jan 2026
Contributed by Lukas
When making or receiving a gift in Portugal, a common question is who actually pays the tax. In this episode, we explain how Portuguese law allocates ...
Does Portugal Have A Gift Tax?
19 Jan 2026
Contributed by Lukas
Portugal is often described as having “no gift tax”—but that statement needs context. In this episode, we explain how gifts are actually taxed i...
Can Non-Residents Benefit From Regional ISD Reductions In Spain?
18 Jan 2026
Contributed by Lukas
Spanish Inheritance and Gift Tax (ISD) is heavily influenced by regional tax benefits, but for years those benefits were largely denied to non-residen...
Gift Tax In Spain When Both Donor And Donee Are Non-Residents
17 Jan 2026
Contributed by Lukas
What happens when neither the donor nor the recipient is resident in Spain—but the gifted asset is located there? In this episode, we explain when S...
Is A Spanish Donor Taxed When Giving A Gift To A Non-Resident?
16 Jan 2026
Contributed by Lukas
A frequent point of confusion in cross-border gifting is whether a Spanish-resident donor becomes liable to Spanish gift tax when making a gift to a n...
Gifts From Abroad: Spanish Tax Implications
15 Jan 2026
Contributed by Lukas
When gifts cross borders, Spanish gift tax rules can quickly become complex. In this episode, we explain when Spanish Gift and Inheritance Tax (ISD) a...
Does Spain Tax Gifts On A Worldwide Basis?
14 Jan 2026
Contributed by Lukas
Gift taxation in Spain depends on who receives the gift and where they are tax resident. In this episode, we clarify when Spain applies gift tax on a ...
Gift Taxation in Spain, Portugal & France
13 Jan 2026
Contributed by Lukas
Gift taxation across Europe often creates confusion—especially in cross-border situations. In this episode, we unpack how Spain, Portugal, and Franc...
Why Custodial Institutions Are Not Look-Through Entities
12 Jan 2026
Contributed by Lukas
Automatic Exchange of Information (AEOI) under CRS/FATCA is highly structured and tiered. It is designed to allocate reporting once—not duplicate it...
Custodial Institution Settles a Cook Islands Trust
11 Jan 2026
Contributed by Lukas
Can a custodial institution legally settle a Cook Islands trust—and what does that mean for FATCA and CRS reporting? In this episode, we walk throug...
A Superior Structure to the Cook Islands Trust?
10 Jan 2026
Contributed by Lukas
From time to time, structures are presented as being “stronger” or “more private” than a traditional Cook Islands trust. In this episode, we c...
Why Cook Islands Trusts Can Be Unsuccessful in U.S. Courts
09 Jan 2026
Contributed by Lukas
Cook Islands trusts are often described as legally robust under offshore law—yet some have still ended badly for settlors in U.S. courts. In this ep...
Contempt of Court Cases and Cook Islands Trusts
08 Jan 2026
Contributed by Lukas
Cook Islands trusts are often marketed as impenetrable asset-protection tools—but U.S. court records tell a more nuanced story. In this episode, we ...
Criticisms of Cook Islands Trusts
07 Jan 2026
Contributed by Lukas
Cook Islands trusts are frequently presented as the strongest form of asset protection available—but they are not immune from criticism or regulator...
How Cook Islands Trusts Protect Assets Like a Fortress
06 Jan 2026
Contributed by Lukas
Cook Islands trusts are often described as the “fortress” of asset protection—but what does that really mean in legal terms? In this episode, we...
Limitations of the Cook Islands Trust
05 Jan 2026
Contributed by Lukas
Cook Islands trusts are powerful asset-protection tools, but they are not magic shields. In this episode, we take a clear-eyed look at the limitations...
Who Typically Uses a Cook Islands Trust
04 Jan 2026
Contributed by Lukas
Cook Islands trusts are not one-size-fits-all solutions. They are typically used by individuals who face elevated legal, professional, or commercial r...
Cook Islands Trust: Core Asset Protection Features
03 Jan 2026
Contributed by Lukas
Cook Islands trusts are widely regarded as one of the most robust asset-protection vehicles in the world—but why? In this episode, we break down the...
Cook Islands Trust: Key Asset Protection Benefits
02 Jan 2026
Contributed by Lukas
Why do Cook Islands trusts continue to be referenced in serious asset-protection planning discussions? In this episode, we break down the core legal p...
Portugal’s Vacant Housing Issue: Government Measures Under Discussion
30 Dec 2025
Contributed by Lukas
Portugal’s high level of vacant housing continues to attract political and public attention—but what is actually happening at policy level? In thi...
Wills and Forced Heirship in Portugal: What You Need to Know
29 Dec 2025
Contributed by Lukas
Estate planning in Portugal follows a civil law tradition that places strong protections around family inheritance rights. In this episode, we explain...
Heirs in Portugal: Key Documents to Begin the Inheritance Process
28 Dec 2025
Contributed by Lukas
When inheriting property in Portugal, taxes are often a major concern—especially for international families. In this episode, we clarify how Stamp D...
Habilitação and Property Fees for Heirs in Portugal: What to Expect
27 Dec 2025
Contributed by Lukas
When inheriting property in Portugal, understanding the costs involved is just as important as understanding the legal steps. In this episode, we brea...
Inheriting Property in Portugal: Stamp Duty
25 Dec 2025
Contributed by Lukas
When inheriting property in Portugal, taxes are often a major concern—especially for international families. In this episode, we clarify how Stamp D...
Why Are There So Many Vacant Properties in Portugal?
23 Dec 2025
Contributed by Lukas
Portugal is often described as facing a housing shortage—yet walk through many towns and cities and you’ll see countless empty homes. So what expl...
Are Foreign Wills Valid for Assets in Portugal?
22 Dec 2025
Contributed by Lukas
When international families own property or other assets in Portugal, one critical question often arises: Will a foreign will be recognised under Port...
Taxes and Fees When Buying Real Estate in Portugal
21 Dec 2025
Contributed by Lukas
Buying property in Portugal involves more than just the purchase price. In this episode, we walk through the key taxes and fees every buyer—local or...
Does Portugal Have Inheritance Taxes?
20 Dec 2025
Contributed by Lukas
Inheritance taxation is one of the most common—and misunderstood—questions when dealing with estates in Portugal. In this episode, we clarify how ...
How Long Does Probate Really Take in Portugal?
19 Dec 2025
Contributed by Lukas
When someone dies owning assets in Portugal, one legal step is often unavoidable: the habilitação de herdeiros. In this episode, we explain what thi...
What Is the Habilitação de Herdeiros in Portugal and When Is It Needed?
18 Dec 2025
Contributed by Lukas
When someone dies owning assets in Portugal, one legal step is often unavoidable: the habilitação de herdeiros. In this episode, we explain what thi...
What Is the First Step When Someone Dies Owning Property in Portugal?
17 Dec 2025
Contributed by Lukas
Navigating inheritance procedures in a foreign country can feel overwhelming, especially when real estate is involved. In this episode, we unpack the ...
Structuring Property Ownership to Minimize International Reporting
16 Dec 2025
Contributed by Lukas
As global transparency frameworks expand to include real estate, many high-net-worth families and advisors are reassessing how property ownership stru...
Detailed Reporting: Information Exchanged on Immovable Property Assets
15 Dec 2025
Contributed by Lukas
As countries adopt the IPI MCAA framework, one of the most important questions is: What exactly will be shared?In this episode, we break down the full...
Timing of Real Estate Information Exchange: Annual Reporting Explained
14 Dec 2025
Contributed by Lukas
How often will countries exchange real estate information under the new transparency framework? In this episode, we break down the reporting timelines...
Reciprocity in International Property Information Exchange Explained
13 Dec 2025
Contributed by Lukas
Reciprocity sits at the heart of global tax transparency. Without it, information exchange systems would be unbalanced, inconsistent, and difficult to...
Why Only Readily Available Real Estate Information Is Collected and Exchanged
12 Dec 2025
Contributed by Lukas
As governments work to strengthen global tax transparency, the exchange of real estate information has become a new priority. But instead of creating ...
Understanding the Exchange of Readily Available Real Estate Information
11 Dec 2025
Contributed by Lukas
As global tax authorities continue to strengthen transparency frameworks, real estate has emerged as a critical area in need of more consistent report...
The Legal Basis for Exchanging Real Estate Information Explained
10 Dec 2025
Contributed by Lukas
Over the past decade, global tax transparency has undergone a major transformation. Since 2010, new international standards and agreements have dramat...
Origins of Real Estate Information Exchange: How the G20 Sparked Global Transparency
09 Dec 2025
Contributed by Lukas
Global tax transparency didn’t happen overnight—it began with a bold statement from G20 leaders in 2009 to end bank secrecy. That declaration set ...
Why Introduce Automatic Exchange of Information on Real Estate and Related Recurring Income?
08 Dec 2025
Contributed by Lukas
Why is real estate becoming the next major focus in global tax transparency? In this episode, we break down the growing push—led strongly by India w...
Three Reasons Governments Are Targeting The Wealthy And What Wealthy Families Should Do
07 Dec 2025
Contributed by Lukas
Around the world, governments are quietly shifting their tax strategies — moving away from corporate taxation and turning their attention to private...
Power of Attorney Validity in the UAE
06 Dec 2025
Contributed by Lukas
In this episode, we unpack everything you need to know about Power of Attorney (POA) validity in the UAE—how long it lasts, when it expires, and why...
UAE Probate Timelines: With vs. Without a Will
05 Dec 2025
Contributed by Lukas
Timing matters when it comes to probate in the UAE—and having a Will can make all the difference.✅ With a WillProbate is streamlined, usually wrap...
How Often Should You Review Your Will in the UAE?
04 Dec 2025
Contributed by Lukas
Your life changes—and your Will should change with it.As a general rule, it’s smart to review your Will every 5 years. If you like to stay especia...
Updating or Amending Your Will in the UAE
03 Dec 2025
Contributed by Lukas
Life circumstances change, and your Will may need to be updated. How you do this depends on where the Will is registered:DIFC WillCan be amended at an...
What You Need to Register a Will in the UAE
02 Dec 2025
Contributed by Lukas
Preparing a Will in the UAE is a straightforward process, whether you choose DIFC, ADJD, or Dubai Courts. The key is gathering the correct documents b...
When to Use a Power of Attorney in the UAE
01 Dec 2025
Contributed by Lukas
A Power of Attorney (POA) is often confused with a Will, but the two serve entirely different purposes.POA vs. WillA POA is valid only during the life...
Assets Covered by a Will in the UAE
30 Nov 2025
Contributed by Lukas
A UAE Will can cover a wide range of assets, giving individuals full control over how their estate is distributed and ensuring a smooth probate proces...
When to Use a Power of Attorney in the UAE
29 Nov 2025
Contributed by Lukas
A Power of Attorney (POA) is one of the most useful legal tools in the UAE, but it is often misunderstood. A POA does not replace a Will, and the two ...
Using a Foreign Will in the UAE: What You Need to Know
28 Nov 2025
Contributed by Lukas
You can absolutely keep your home-country Will valid while living in the UAE. In fact, many expatriates maintain a foreign Will for overseas assets wh...