Understanding Cross-Border Wealth Structuring for Multi-Market Investors

Cross-Border Wealth Structuring: What It Is and Why It Matters Now

If you’ve built a portfolio spanning US equities, London property, and an Asian operating business, you already know that managing wealth across borders is more complex than simply picking the right investments. The rules have changed dramatically since 2010, and what worked a decade ago can now trigger unexpected tax bills, reporting penalties, or worse.

Cross-border wealth structuring refers to the deliberate coordination of ownership, tax residence, and legal vehicles—trusts, holding companies, funds, and other entities—across at least two jurisdictions. It’s not about hiding assets or aggressive tax avoidance. Instead, it’s about organizing your global footprint in a way that aligns with the regulatory frameworks of every country where you live, invest, or hold assets.

This coordination has become critical in the post-FATCA era (2010 onwards) and especially after the Common Reporting Standard (CRS) rolled out globally from 2014. Before these regimes, cross border investments could exist in relative isolation. Now, financial institutions in over 100 countries automatically share account information with tax authorities worldwide. Add in the geopolitical volatility and rapid tax policy changes since 2022, and ad-hoc approaches simply don’t work anymore.

Multi-market investors typically hold a mix of US ETFs or direct equities, London or European real estate, and operating businesses or venture investments in Asia. Each of these creates overlapping tax and reporting duties. A dividend from a US stock may be subject to withholding tax, reportable under FATCA if you’re a US person, and potentially taxable again in your country of residence. Your London flat may trigger UK inheritance tax for your heirs, regardless of where they live. Your Singapore business may create permanent establishment issues if managed from the wrong location.

This article focuses specifically on high-net-worth individuals and family offices with assets in excess of USD 10 million spread across multiple markets. If that describes your situation—or the clients you advise—what follows is a practical roadmap for building, maintaining, and optimizing cross border wealth structures that can withstand regulatory scrutiny while supporting your financial objectives.

Global Investing Landscape for Multi-Market Investors

Private investors today commonly allocate capital to US, EU, UK, and Asian markets simultaneously. This isn’t a new trend, but the intensity of global allocation has accelerated since 2015. Access to previously restricted asset classes—US private credit funds, Irish-domiciled UCITS, London and Dubai real estate, Southeast Asian tech startups—has fundamentally changed how portfolios are constructed.

The regulatory backdrop driving this landscape includes three major regimes that every wealth manager must understand:

• FATCA (2010): The US Foreign Account Tax Compliance Act requires foreign financial institutions to report accounts held by US citizens and residents, with 30% withholding penalties for non-compliance.

• CRS (2017 rollout): The Common Reporting Standard enables automatic exchange of financial account information among 100+ jurisdictions, making offshore secrecy largely obsolete.

• EU Substance Rules (2019 onwards): Post-BEPS reforms require entities in Luxembourg, Ireland, Cyprus, and other jurisdictions to demonstrate real economic presence—boards that meet, staff that work, decisions made locally.

Wealth managers reconciling these rules must navigate fundamentally different tax models. The US uses citizenship based taxation, meaning US citizens and green card holders owe tax on worldwide income regardless of where they live. Europe and Asia primarily use residence-based taxation, where your tax home determines your obligations. Territorial systems in Hong Kong and Singapore often exempt foreign-source income entirely. Getting the interaction wrong can result in double taxation or, conversely, unnecessary tax exposure that a proper structure would eliminate.

A sample “global” individual portfolio might look like this:

• US large-cap equities held via Irish-domiciled ETFs

• London residential property held personally or via a UK company

• Singapore-based discretionary portfolio of Asian equities

• Private credit fund investments in US and European managers

• Direct stake in a Hong Kong trading company

Each component has distinct tax implications in the investor’s country of residence, the country where assets are located, and potentially the country of the investor’s citizenship.

Core Building Blocks of a Cross-Border Wealth Structure

Effective wealth structures combine legal entities, holding vehicles, and governance arrangements into a coherent architecture. The goal isn’t complexity for its own sake—it’s ensuring that every component serves a clear purpose for tax efficiency, asset protection, or succession planning.

The interaction of three factors determines your tax exposure across different countries:

1. Residency of the individual: Where you live and pay tax as your primary home

2. Location of the assets: Where property sits, where companies operate, where investments are custodied

3. Place of incorporation of entities: Where your holding companies, trusts, or funds are legally established

Double tax treaties, estate tax treaties, and information exchange agreements modify how these factors interact. A well-chosen structure can access treaty benefits that reduce withholding tax on dividends from 30% to 15% or even 0%. A poorly chosen structure might trigger tax in three jurisdictions instead of one.

Common building blocks include:

• Holding companies (Singapore, Luxembourg, UAE): Centralize ownership of global investments, access treaty networks, defer taxation at the individual level

• Trusts (Jersey, Guernsey, Cayman): Provide asset protection, privacy, and succession planning benefits under common law systems

• Foundations (Liechtenstein, Panama): Serve similar purposes in civil law jurisdictions where trusts may not be recognized

• Funds and managed accounts (Ireland, Luxembourg): Pool investments with tax-efficient treatment for cross-border investors

• Insurance wrappers (Luxembourg, Isle of Man): Provide tax deferral and privacy for portfolio investments

• Family governance structures: Constitutions, councils, and charters that formalize decision-making across generations

Key Legal Vehicles: Holding Companies, Trusts, and Foundations

A Singapore or Luxembourg holding company can serve as the central node of a global investment structure, owning stakes in portfolio companies, private equity funds, and real estate SPVs across multiple regions. The choice between these jurisdictions often depends on where the underlying assets are located and which tax treaties provide the most favorable treatment.

Singapore offers an extensive treaty network across Asia, no capital gains tax, and a territorial system that can exempt foreign-source dividends. Luxembourg provides access to the EU Parent-Subsidiary Directive, which eliminates withholding tax on dividends between EU entities, plus over 80 double tax treaties globally.

The distinction between common-law trusts and civil law jurisdictions foundations matters significantly for international families. A Cayman STAR trust or Jersey discretionary trust operates under principles developed over centuries in English law—the settlor transfers assets to trustees who hold them for beneficiaries according to the trust deed. A Liechtenstein family foundation, by contrast, is a legal entity in its own right, with its own personality under civil law, governed by foundation council rather than trustees.

Typical purposes for these vehicles include:

• Asset protection: Shielding family wealth from creditor claims, divorce proceedings, or political expropriation

• Privacy: Limiting public disclosure of beneficial ownership in jurisdictions with strong confidentiality

• Consolidation of reporting: Simplifying the annual compliance burden by holding multiple assets through a single structure

• Intergenerational planning: Transferring wealth across generations while managing estate and gift tax exposure

A simple ownership flow might work as follows: the individual (or a trust of which they are the settlor) owns a Singapore holding company, which in turn owns operating businesses in Hong Kong, a real estate SPV in London, a portfolio of Irish ETFs, and LP interests in US private credit funds. Each layer serves a specific purpose—the trust for succession, the holding company for tax efficiency and centralized control, the SPVs for liability ring-fencing.

Choosing Where to Hold Assets: Jurisdiction and Tax Residence

Investors must carefully distinguish three separate concepts that are often confused:

• Where you live (tax residency): Determines which country has primary taxing rights over your worldwide income

• Where entities are incorporated: Determines which country’s corporate law governs your companies and trusts

• Where assets are located: Determines which country may tax gains on disposal or apply estate taxes on death

A French tax resident with a UK investment property held via a Luxembourg company faces a different set of obligations than a UAE resident holding the same property directly. The French resident must consider French taxation of the Luxembourg company’s income (potentially under CFC rules), UK taxation of rental income and gains, and Luxembourg’s substance requirements for the holding company. The UAE resident, by contrast, may face only UK tax on UK-source income, with no personal tax in the UAE.

Bilateral tax treaties can reduce withholding tax rates significantly:

• The Luxembourg-France treaty can reduce dividend withholding to 5% for substantial holdings

• The UAE-India treaty provides favorable treatment for investments flowing between those jurisdictions

• The UK-India treaty governs taxation of dividends, interest, and capital gains between those countries

Scenario 1: Inappropriate jurisdiction choice triggers double taxation

A German resident holds US dividend-paying stocks directly in a US brokerage account. The US withholds 30% on dividends under FATCA (reducible to 15% under the US-Germany treaty if proper forms are filed). Germany taxes the dividends again at the individual’s marginal rate, giving a credit for the US tax paid. If the investor had instead held Irish-domiciled ETFs that invest in US stocks, the ETF would suffer only 15% US withholding on dividends it receives, and the investor would owe German tax on distributions from the ETF—often a more tax efficient outcome.

Scenario 2: Estate tax exposure from direct US holdings

A Singapore resident holds $5 million in US equities directly. On death, the estate faces US estate tax on these US-situs assets. The estate tax exemption for foreign investors is only $60,000—far below the $13+ million exemption available to US citizens. The estate could owe over $1.5 million in US estate tax. Holding the same exposure via Irish ETFs would eliminate this risk, as the ETF shares are not US-situs assets.

Scenario 3: Forced heirship conflicts

A Spanish resident creates a Jersey trust to hold global assets, intending to distribute wealth unequally among children based on need. Spanish forced heirship rules, however, require that a portion of the estate pass to all children equally. Without careful planning to address this conflict, the trust could be challenged by disinherited children under Spanish law.

Tax Optimization and Regulatory Alignment Across Borders

Balancing tax efficiency with regulatory compliance and reputational risk defines modern cross border structuring. The post-BEPS environment (OECD Base Erosion and Profit Shifting project, 2015 onwards) has eliminated many aggressive planning techniques that were once commonplace. Structures that lack economic substance, serve no purpose beyond tax reduction, or rely on mismatches between jurisdictions now face significant challenge from tax authorities.

That said, legitimate tax planning remains entirely appropriate. Tax treaties exist precisely to prevent double taxation and to allocate taxing rights between countries. Using these treaties as intended is not aggressive—it’s sensible wealth management.

Common tax planning levers for cross-border investors:

• Treaty relief on dividends: Reducing withholding tax from 30% to 15% or lower by holding through treaty-eligible structures

• Portfolio interest exemption: US-source interest on qualifying debt is exempt from withholding for foreign investors

• Participation exemption regimes: Luxembourg, Netherlands, and Singapore exempt dividends and capital gains from qualifying subsidiaries

• Irish-domiciled ETFs: Access US equity markets with reduced withholding and no US estate tax exposure

• Debt vs. equity structuring: Interest payments are often deductible at the payer level and may face lower withholding than dividends

Substance requirements have become the critical gating factor. Jurisdictions like Luxembourg, Ireland, and Singapore now require entities to demonstrate genuine economic presence:

• Board meetings held in the jurisdiction with local directors

• Qualified staff employed locally to manage the entity’s activities

• Key decisions made in the jurisdiction, documented in minutes

• Adequate premises and operating expenditure

Transparent, well-documented structures are essential to withstand tax authority audits, particularly with CRS enabling automatic exchange of information. A structure that looks artificial or lacks supporting documentation will attract scrutiny. Many advisors now recommend “substance over form” as the guiding principle—if a structure doesn’t make commercial sense beyond tax savings, don’t use it.

Dividend, Interest, and Capital Gains: Practical Tax Considerations

Understanding how different income types are taxed across borders is fundamental to structuring decisions.

Dividends: When a foreign investor receives dividends from a company, the source country typically withholds tax. The US withholds 30% on dividends paid to foreign investors, reducible to 15% or lower under tax treaties. The investor’s home country may then tax the dividend again, potentially giving a credit for withholding tax paid.

Interest: Many countries exempt or reduce withholding on interest payments. The US portfolio interest exemption allows foreign investors to receive interest on US bonds and bank deposits free of withholding tax, provided certain conditions are met. This makes US Treasuries and qualifying corporate bonds attractive for non-US investors.

Capital gains: Treatment varies dramatically by residence. UK and French residents face tax on worldwide capital gains, including gains on foreign assets. Singapore residents are generally exempt from tax on capital gains, whether domestic or foreign. Hong Kong applies no capital gains tax at all.

Practical strategies include:

• Routing dividend-paying equity investments through Irish UCITS funds, which benefit from reduced US treaty rates and are not US-situs for estate tax purposes

• Using Luxembourg SICAVs for European equity exposure, benefiting from EU directives and Luxembourg’s treaty network

• Holding US Treasuries directly to benefit from portfolio interest exemption (no withholding) while avoiding FDAP complications

• Structuring private company holdings through jurisdictions with participation exemptions to eliminate tax on eventual exit gains

Managing US Exposure: Estate Tax, FDAP, and Private Markets

The United States presents unique challenges for foreign investors that require careful planning. Unlike most countries, the US applies estate tax to non-residents based on where assets are located, not where the investor lives.

Non-US persons face a US estate tax exemption of only USD 60,000 on US-situs assets—compared to over USD 13 million for US citizens and residents in 2024. This exemption is scheduled to drop by roughly half in 2026 when provisions of the Tax Cuts and Jobs Act (TCJA) enacted in 2017 expire. For a foreign investor with $10 million in US stocks held directly, the potential estate tax liability exceeds $3.5 million.

FDAP income (fixed, determinable, annual, or periodic) includes dividends, interest (other than portfolio interest), rents, and royalties from US sources. Foreign investors face 30% withholding on FDAP income unless a treaty reduces the rate. Treaty benefits require proper documentation—W-8BEN forms filed with custodians—and may be denied if forms are not current.

Methods to manage US exposure include:

• Portfolio interest exemption: Hold qualifying US bonds directly to receive interest free of withholding

• Irish-domiciled ETFs: Gain US equity exposure without US estate tax risk or direct FDAP withholding

• Jurisdiction-specific holding companies: Some investors use entities in treaty jurisdictions to hold US investments, though substance requirements and limitation-on-benefits clauses must be carefully analyzed

• Life insurance wrappers: Certain structures can provide tax deferral and estate planning benefits, though complexity and costs are significant

Private markets present additional considerations:

US private credit funds, Business Development Companies (BDCs), Closed-End Funds (CEFs), and venture capital funds often generate income that is taxed unfavorably for foreign investors. Many funds use “blocker corporations”—US C corporations that hold the investment and convert pass-through income into dividends—to address these issues. Offshore feeder funds structured as corporations can serve similar purposes.

Non-US family offices investing in US private markets should work with advisors who understand both US tax law and the investor’s home country treatment of these structures. Getting it wrong can result in double taxation or, worse, unexpected US tax filing obligations.

Preserving and Protecting Cross-Border Wealth

Preserving capital across different jurisdictions has become harder due to political risk, exchange controls, and rapidly changing tax regimes. The strategies that protected family wealth a generation ago—simply holding assets offshore—no longer suffice in an era of automatic information exchange and global transparency.

Modern asset protection requires a multi-layered approach:

Diversification by asset class

• Public markets (equities, bonds) for liquidity and growth

• Private credit and private equity for yield and diversification

• Real estate for tangible value and inflation protection

• Venture capital for long term growth exposure

• Cash and equivalents for liquidity needs

Diversification by geography

• US markets for depth and sector diversity

• Europe for brand-name multinationals and stability

• Asia for growth and demographic tailwinds

• Middle East (UAE, Saudi) for emerging allocations

• Stable jurisdictions (Switzerland, Singapore) for holding structures

Diversification by currency

• USD as the global reserve currency

• EUR for European-based expenses and liabilities

• CHF and SGD for stability

• Local currencies where operationally necessary

Asset protection strategies using trusts, foundations, and insurance wrappers can shield wealth from creditor claims, political expropriation, and family disputes. A properly structured Cayman STAR trust or Liechtenstein foundation, settled when the settlor is solvent and without intent to defraud creditors, can provide significant protection against future claims.

Regulatory risks in emerging markets—exchange controls, capital restrictions, asset freezes—can be mitigated through offshore structures. A Singapore or Hong Kong holding company owning assets in higher-risk jurisdictions provides a layer of legal and practical protection that direct ownership does not.

Succession and Intergenerational Planning Across Jurisdictions

International families often have members living in the US, UK, EU, and Asia simultaneously. This creates conflicting inheritance and forced-heirship rules that must be navigated with careful planning.

A US citizen married to a French resident spouse, with children studying in Singapore, faces at least three legal systems:

• US estate and gift tax applies to the US citizen’s worldwide assets, with limited marital deduction for transfers to a non-US spouse

• French forced heirship rules may require that children receive a minimum share of the estate regardless of the deceased’s wishes

• Singapore has no estate duty but the children’s eventual tax residence will affect how they receive and hold inherited assets

Tools for managing succession across borders include:

• Foreign Grantor Trusts (FGTs): A non-US trust treated as owned by a US person for tax purposes, providing estate planning benefits while avoiding adverse US tax treatment of trust distributions

• Foreign Non-Grantor Trusts (FNGTs): Trusts that are not owned by the grantor for US tax purposes, useful for non-US settlors with US beneficiaries

• Testamentary trusts: Trusts created by will that take effect on death, allowing flexibility in planning for different jurisdictions

• Family charters and family councils: Governance documents that establish decision-making processes, conflict resolution mechanisms, and family governance principles across generations

Specific issues to address include:

• US estate and gift tax for US persons (including green card holders and those meeting substantial presence tests)

• Forced heirship in civil law jurisdictions (France, Spain, Italy, and many Latin American countries)

• Sharia-based succession rules in Gulf states, which may override wills for Muslim decedents

• UK inheritance tax, which applies to UK-domiciled individuals on worldwide assets and to UK-situs assets regardless of domicile

Coordinated wills in multiple jurisdictions are essential. A will valid in one country may not be recognized in another, and conflicting provisions can create legal disputes that consume wealth rather than transfer it. Trust deeds and company bylaws should align with testamentary documents to ensure smooth wealth transfer to future generations.

Composite example: A US citizen entrepreneur sells a tech company and relocates to Dubai with her British husband. Their children are at university in the US and UK. The family’s wealth includes proceeds from the sale (held in a Singapore discretionary portfolio), London residential property, and remaining equity in a follow-on venture in California.

Without planning, the US citizen remains subject to US estate tax on worldwide assets, the London property is exposed to UK inheritance tax, and the California equity could trigger both US and UK taxation on death. A coordinated plan might include a US domestic trust for US assets, an offshore structure for non-US holdings, and aligned wills in the US and UK addressing each component.

Currency, Banking, and Liquidity Risks

Holding assets in USD, EUR, GBP, CHF, and local currencies creates currency risk that must be actively managed. A euro-based investor with USD private credit income faces FX exposure on every distribution. A sudden 10% move in exchange rates can eliminate a year’s yield.

Managing currency risk:

• Natural matching: Hold assets in currencies that match expected liabilities (e.g., EUR assets for EUR-based living expenses)

• Hedging: Use forward contracts or options to lock in exchange rates for known cash flows

• Diversification: Accept that some currency exposure is the price of global diversification, but avoid concentration

Cross-border banking has become more challenging since 2015 due to de-risking by major private banks. Clients with US connections (citizenship, residency, or substantial US assets) may find European or Asian banks reluctant to open accounts. Clients with links to high-risk jurisdictions face enhanced due diligence that can take months.

Liquidity management requires ensuring that cash is available in the right currency and jurisdiction to meet:

• Annual tax bills in each country of residence or asset location

• Margin calls on leveraged investments

• Estate settlement costs, which may need to be paid before beneficiaries can access assets

• Emergency relocation or regulatory crackdown scenarios

A euro-based investor with substantial USD private credit income should maintain USD liquidity facilities to meet tax obligations and distributions without forced currency conversion at unfavorable rates.

Compliance, Reporting, and Substance Requirements

CRS and FATCA form the backbone of today’s cross-border transparency regime. Their enforcement has ramped up significantly between 2017 and 2023, with financial institutions worldwide now routinely reporting account balances and income to tax authorities.

Common reporting obligations for individuals:

• FBAR (FinCEN 114): US persons with foreign financial accounts exceeding $10,000 in aggregate must file annually by April 15 (with automatic extension to October)

• Form 8938: US persons with specified foreign financial assets exceeding $50,000 ($200,000 for those living abroad) must report on their tax return

• French foreign asset reporting: French residents must declare foreign bank accounts, life insurance contracts, and trust relationships

• Spanish Model 720: Spanish residents must report overseas assets exceeding €50,000 in any category

• Italian RW reporting: Italian residents must report foreign financial assets and investments annually

Corporate substance requirements have intensified:

• Luxembourg requires holding companies to have local directors, maintain premises, and document board meetings

• Cyprus entities must demonstrate management and control in Cyprus to claim treaty benefits

• Caribbean financial centers face EU blacklist scrutiny if they cannot show adequate substance

• Ireland requires funds and holding companies to have locally resident directors and genuine decision-making presence

Technology platforms now help consolidate multi-jurisdictional tax data and produce regulatory reports. Many advisors and family offices use specialized software to track reporting deadlines across countries, maintain documentation, and ensure compliance with local filing requirements.

Key deadlines and regimes:

• CRS reporting by financial institutions occurs annually, typically in spring following the reporting year

• US FBAR deadline is April 15 with automatic extension to October 15

• Many European countries require foreign asset disclosure with annual tax returns (March-June deadlines)

• Penalties for non-compliance can reach $100,000+ per violation for willful failures

Managing Regulatory Risk in Cross-Border Structures

Poorly designed structures can accidentally trigger issues that were never intended:

Permanent Establishment (PE) risks: If a foreign company’s activities in a country rise to the level of a PE—typically through employees, agents, or premises in that country—the company may become subject to local corporate tax. Even private investors can create PE issues if their holding companies are managed from the wrong location.

Transfer pricing questions: Transactions between related entities (e.g., loans from a holding company to an operating subsidiary) must be priced at arm’s length. Tax authorities increasingly scrutinize related-party transactions, even in purely private structures.

Securities law concerns: Non-US family offices that pool capital from US persons may inadvertently trigger registration requirements under the Investment Advisers Act. The “family office exemption” is narrow and requires careful compliance.

Red flags that attract scrutiny:

• Shell entities with no board meetings, no premises, and no local substance

• Inconsistent tax filings across countries (e.g., claiming residence in multiple jurisdictions)

• Structures that appear designed solely for tax reduction with no commercial rationale

• Directors who serve on hundreds of boards and cannot meaningfully oversee each entity

• Missing documentation for historic transactions or corporate decisions

Authorities scrutinize beneficial ownership, economic purpose, and substance to challenge artificial arrangements. Structures that cannot withstand this scrutiny may be “looked through” by tax authorities, resulting in taxation as if the structure did not exist.

Designing and Implementing a Cross-Border Wealth Strategy

Building a cross-border wealth structure requires a systematic approach. Rushing to implement strategies without understanding the full picture creates more problems than it solves.

Step-by-step implementation framework:

1. Map assets and residencies: Document every asset, its location, its legal ownership, and the tax residence of all family members. Include citizenship, domicile, and pending relocations.

2. Identify tax and legal constraints: Analyze the tax treatment of each asset in each relevant jurisdiction. Identify forced heirship rules, exchange controls, and reporting obligations.

3. Define goals: Clarify priorities—current income, long-term growth, control, privacy, legacy. Different goals may require different structures.

4. Design structures: Develop a target architecture using holding companies, trusts, and funds in appropriate jurisdictions. Stress-test against tax challenges and family scenarios.

5. Implement and document: Establish entities, transfer assets, and create comprehensive documentation including trust deeds, shareholders’ agreements, and family governance documents.

6. Review annually: Reassess the structure against changes in law, family circumstances, and investment portfolios. Update documentation and filings.

Coordinated team requirements:

A proper cross-border structure requires many advisors working together:

• International tax counsel in the investor’s residence jurisdiction

• Local lawyers in each country where significant assets are held

• Trust company or corporate service provider in the jurisdiction of holding entities

• Investment advisors with cross-border experience

• Private banks capable of servicing multi-jurisdictional clients

• Accountants who can coordinate filings across countries

Typical timelines run 3–6 months for initial structuring, longer for complex reorganizations or migrations of existing trusts and companies. Rushed implementations often miss critical details.

Stress-testing is essential:

• What happens if a family member relocates to a new country?

• How does the structure perform if a key jurisdiction changes its tax law?

• What are the estate tax implications if the primary wealth holder dies unexpectedly?

• How would the structure handle a major investment exit?

• What happens in 2026 when the US estate tax exemption changes?

Common Pitfalls for Multi-Market Investors

Recurring errors can undermine even well-intentioned structures:

Ignoring US tax rules when acquiring US assets: Non-US investors frequently underestimate US estate tax exposure and FDAP withholding. Acquiring US real estate directly, without considering the $60,000 estate tax exemption, is a common and costly mistake.

Holding operational businesses directly: Operating companies should generally be held through holding companies that provide liability protection, tax efficiency, and succession flexibility. Direct ownership creates unnecessary tax exposure and complicates eventual sale or transfer.

Neglecting estate tax exposure on foreign property: UK inheritance tax applies to UK property regardless of the owner’s residence. London real estate held by non-UK residents is fully exposed unless structured through appropriate vehicles (with increasingly limited options post-2017).

Over-complex structures: Structures with multiple layers, dozens of entities, and convoluted ownership chains create unmanageable reporting burdens, increase advisory costs, and raise audit risk. Simplicity, where possible, is a virtue.

Residency mistakes: Accidental tax residence in the UK (183-day rule plus ties) or Spain (183 days or “center of vital interests”) can have dramatic tax consequences. Careful planning and day-counting are essential for mobile families.

Non-aligned wills: Wills drafted in isolation for each country may conflict with each other or with trust deeds and company bylaws. Coordination is essential to prevent penalties and legal disputes that consume family wealth.

Static structures in a changing world: The recent tightening of UK non-dom rules, changes to EU blacklists, and ongoing regulatory shifts mean structures must be reviewed regularly. What was optimal in 2018 may be problematic in 2024.

Case Study: Building a Multi-Jurisdiction Wealth Structure

Consider a fictional but realistic family: Chen Wei, an entrepreneur based in Singapore who sold a logistics technology company for $80 million, is married to Sarah, a UK tax resident and British citizen. Their two children are studying at universities in California and London. The family holds assets in Hong Kong (the original operating company’s remaining shares), London (a £4 million residential property where Sarah lives), New York (US equities and a stake in a private credit fund), and Dubai (an investment apartment).

Before: Fragmented Direct Holdings

Chen originally held all assets in his personal name or jointly with Sarah. The US equities were held directly in a US brokerage account, creating estate tax exposure of over $1 million on his death. The London property was held jointly, exposing the full value to UK inheritance tax on the second death. The Hong Kong company was held personally with no succession plan. The Dubai apartment was registered in Chen’s name, subject to UAE succession rules. Each asset had separate advisors in each country, with no coordination.

The Structuring Process

Working with a coordinated team—a Singapore law firm for holding company establishment, Jersey trust specialists, UK tax counsel, and US international tax advisors—the family developed an integrated structure over eight months.

Chen and Sarah established a Jersey discretionary trust with professional trustees, naming their children as beneficiaries. The trust became the shareholder of a Singapore holding company, which in turn owns:

• The Hong Kong company shares (benefiting from Singapore’s participation exemption on dividends and gains)

• A Luxembourg investment vehicle holding European and Asian equities

• An Irish-domiciled ETF platform providing US equity exposure without US estate tax risk or direct FDAP complications

• A UAE company holding the Dubai apartment (addressing local succession rules)

The London property presented more complexity due to recent UK rule changes targeting offshore structures holding UK residential property. After analysis, the family concluded that direct ownership by Sarah (a UK resident) with appropriate life insurance to cover potential IHT was more efficient than complex offshore structures that would trigger the Annual Tax on Enveloped Dwellings and related charges.

After: Coherent Cross-Border Structure

The restructured architecture provides:

• Reduced US estate tax risk: Irish ETFs replace direct US equity holdings

• Treaty relief: Singapore holding company accesses Singapore’s treaty network for Asian investments

• UK inheritance tax planning: Life insurance provides liquidity for IHT on the London property; other assets are held outside the UK estate

• Succession planning: The Jersey trust provides for wealth transfer to future generations while managing US tax implications for children who may remain in the US

• Family governance: A family charter documents decision-making principles, roles of family councils, and mechanisms for conflict resolution

The family now has annual review meetings with their advisory team, coordinate reporting across jurisdictions through a single family office, and maintain documentation that would withstand regulatory scrutiny.

Conclusion: Building Resilient Cross-Border Wealth for the Next Decade

Thoughtful cross border structuring improves tax efficiency, reduces regulatory risk, and supports global family goals. It’s not about finding loopholes or hiding assets—it’s about organizing international wealth in a way that respects the rules of every jurisdiction while minimizing friction and maximizing flexibility.

The regulatory environment has fundamentally changed. CRS, FATCA, BEPS, and domestic tax reforms through 2025–2026 make ad-hoc approaches genuinely risky for multi-market investors. Structures that aren’t documented, don’t have substance, or can’t withstand scrutiny may trigger the very tax liability and legal risks they were designed to prevent.

Ongoing reviews every 2–3 years—or after major events such as relocation, business exits, or legislative changes—are essential. The US estate tax exemption change in 2026, evolving UK non-dom rules, and ongoing EU regulatory requirements mean today’s optimal structure may need adjustment tomorrow.

Most importantly, investors should consult coordinated, multi-jurisdictional advisors rather than relying on isolated, single-country opinions. A US tax attorney may not understand Singapore holding company rules. A UK property lawyer may not appreciate US estate tax exposure. A Singapore wealth manager may not know French forced heirship law. Cross border wealth demands cross-border expertise working together.

Looking ahead, wealth hubs like Singapore, the UAE, Switzerland, and the UK will continue evolving their offerings to attract international clients through 2030 and beyond. Singapore’s stability and Asian connectivity, the UAE’s territorial tax system, Switzerland’s privacy traditions, and the UK’s legal infrastructure each serve different client needs. The investors who thrive will be those who understand these options, implement strategies thoughtfully, and maintain the flexibility to adapt as the world changes.

This article is provided for general information only and does not constitute financial, investment, legal, tax, or regulatory advice. Views expressed are necessarily high-level and may not reflect your specific circumstances; you should obtain independent professional advice before acting on any matter discussed.

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