A profound shift is underway in global fiscal policy. After decades of declining emphasis on wealth taxes, governments are renewing and intensifying their focus on taxing private wealth. This change reflects mounting inequality, post-pandemic fiscal strain, and unprecedented levels of international tax coordination.

In this episode, we unpack why wealth is moving to the center of the tax debate—and why this shift looks structural rather than temporary.

In the post-pandemic period, wealth concentration has accelerated, with the top 1% capturing a disproportionate share of new wealth.

This has fueled public and political pressure for redistribution, reflected in movements such as “tax the rich” and in proposals advanced by figures like Elizabeth Warren in the United States and Thomas Piketty in Europe.

The political narrative increasingly frames wealth taxation as a question of fairness and legitimacy, not just revenue.

Governments are now managing:

• Historically high public debt from COVID-19 stimulus

• Major new spending demands linked to the climate transition, defense, and aging populations

Against this backdrop, wealth taxes are seen as a way to raise revenue without significantly increasing taxes on labor or consumption, which are often politically sensitive.

Globalization and digitalization have weakened the effectiveness of corporate income taxation, as profits can be shifted across borders with relative ease.

By contrast, private wealth—particularly real estate, financial assets, and ownership interests—is often:

• Less mobile

• More visible

• Easier to connect to individuals

This makes wealth a more attractive and stable tax base for governments.

Recent international initiatives have significantly changed the enforcement landscape, including:

• The OECD’s Pillar Two global minimum tax

• The Common Reporting Standard (CRS) for automatic exchange of financial information

Led by bodies such as the Organisation for Economic Co-operation and Development, these frameworks have reduced opportunities for concealment and increased transparency—making broader wealth taxation administratively and politically more feasible.

The renewed focus on private wealth taxation is not a short-term political experiment. It reflects:

• Structural fiscal pressures

• Strong public demand

• Improved enforcement tools

• Greater international coordination

For high-net-worth individuals and advisors, this signals a future where wealth—not just income—will be under sustained scrutiny.

The OECD’s Pillar One and Pillar Two reforms represent the most significant overhaul of international corporate taxation in decades. In this episode, we explain what each pillar does, who it affects, and why it matters, particularly in a world shaped by digital business models and globalised markets.

Developed under the auspices of the Organisation for Economic Co-operation and Development, the two pillars aim to modernise how multinational enterprises (MNEs) are taxed and to reduce harmful tax competition between jurisdictions.

Pillar One addresses the challenge of taxing highly digitalised and consumer-facing MNEs that can generate significant profits in a country without a physical presence.

• Amount A

This reallocates a portion of residual profits of the largest and most profitable MNEs to market jurisdictions—where customers or users are located—even if the company has no permanent establishment there.

• Amount B

Amount B introduces a simplified and standardised return for baseline marketing and distribution activities.

Its purpose is to reduce transfer-pricing disputes and ease compliance, particularly for jurisdictions with limited administrative capacity.

Pillar Two establishes a global minimum corporate tax rate of 15% for MNEs with annual consolidated revenue of at least EUR 750 million.

Where profits in a jurisdiction are taxed below the minimum rate, a top-up tax applies to bridge the gap.

Key mechanisms include:

• Income Inclusion Rule (IIR) – top-up tax at the parent entity level

• Undertaxed Profits Rule (UTPR) – backstop rule allocating tax where income is undertaxed

• Qualified Domestic Minimum Top-up Tax (QDMTT) – allows countries to collect the top-up tax domestically

The objective is to curb profit shifting and base erosion, ensuring that large MNEs pay a minimum level of tax regardless of where they operate.

While often discussed together, the pillars address different problems:

• Pillar One reallocates taxing rights

• Pillar Two sets a minimum tax floor

Together, they seek to rebalance the international tax system between residence jurisdictions, market jurisdictions, and low-tax jurisdictions.

Both pillars are being rolled out through a mix of:

• Multilateral conventions

• Domestic legislation

• EU directives (in the case of Pillar Two)

At the same time, technical details continue to evolve, and implementation timelines and political support vary across jurisdictions.

Pillar One and Pillar Two are reshaping international corporate taxation by:

• Expanding taxing rights beyond physical presence

• Establishing a global minimum effective tax rate

• Reducing opportunities for aggressive tax planning

For MNEs, advisors, and policymakers, understanding both the mechanics and the policy intent is now essential.

In cross-border gift planning, the biggest mistakes rarely come from complex law—they come from misalignment. In this episode, we explain why the most significant risk is failing to connect the civil-law act of making the gift with its tax consequences for the recipient.

🔎 What You’ll Learn in This Episode:

Problems often arise when parties focus on executing the gift legally—signing documents, transferring funds, or handing over assets—without fully analysing how the gift will be taxed in the recipient’s jurisdiction.

A gift can be perfectly valid in civil law and still produce unexpected tax exposure.

Cross-border issues typically stem from ignoring one or more of the following:

• Tax residence of the recipient (and sometimes the donor)

• Location (situs) of the asset

• Valuation rules applied at the time of taxation

• Disclosure and reporting obligations, even where no tax is due

Each of these can independently trigger tax—or penalties—if not addressed upfront.

In many jurisdictions, gift tax is imposed on the recipient, not the donor.

As a result, errors made during planning or documentation frequently materialise later as assessments, penalties, or denied reliefs for the donee.

Cross-border gifts sit at the intersection of:

• Civil law

• Tax law

• Conflict-of-law rules

When these are analysed in isolation instead of together, outcomes can diverge sharply from expectations.

The main risk in international gift planning is not complexity—it’s incomplete analysis.

Effective planning requires aligning:

• The legal mechanics of the gift

• The tax rules of each relevant jurisdiction

• The reporting and valuation framework

Failing to do so is one of the most common causes of surprise tax bills in cross-border family transfers.

This episode highlights why successful cross-border gift planning is less about clever structuring—and more about holistic coordination between law, tax, and facts.

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 can arise on a single gift, and why managing that risk is often more complex than for income or capital gains.

🔎 What You’ll Learn in This Episode:

Different countries may assert taxing rights over the same gift based on different connecting factors, including:

• Residence of the donor

• Residence of the recipient

• Location (situs) of the gifted asset

When these criteria overlap across jurisdictions, multiple tax claims can arise simultaneously.

Unlike income tax, treaty protection for inter vivos gifts is very limited.

Most double tax treaties:

• Do not cover gifts at all, or

• Address only inheritances (and even then, incompletely)

As a result, there is often no treaty-based relief mechanism to eliminate double taxation.

Because treaty relief is usually unavailable, advisers must rely primarily on:

• Domestic tax law exemptions and credits

• Territorial vs worldwide taxation rules

• Timing, classification, and documentation of the gift

Outcomes can differ significantly depending on how each jurisdiction’s internal rules interact.

In some cases, EU law principles—particularly the free movement of capital—may limit discriminatory treatment or allow access to reliefs that would otherwise be denied.

However, EU law does not eliminate double taxation by default and applies only in specific circumstances.

In cross-border gifting:

• Yes, the same gift can be taxed more than once

• Treaty protection is usually not available

• Prevention depends on careful planning under domestic law, not automatic relief

• Early analysis of donor residence, donee residence, and asset location is essential

This episode explains why gift taxation requires jurisdiction-by-jurisdiction analysis—and why assuming “there must be a treaty” is one of the most dangerous mistakes in international estate planning.

Not all gifts are created equal under French law. In this episode, we explain how informal or manual gifts—called donations manuelles—are treated for French gift tax purposes and why disclosure matters.

🔎 What You’ll Learn in This Episode:

Donations manuelles are informal gifts made without a notarial deed, such as:

• Cash gifts handed directly to a beneficiary

• Personal property transferred without formal documentation

Unlike notarised gifts, these manual gifts become taxable only when they are disclosed to the French tax authorities. Disclosure can occur via:

• Declaration in a registered document

• Formal recognition by a court

The gift tax is generally based on the market value of the asset at the time of disclosure, not at the time of transfer.

This ensures fair taxation while allowing some flexibility for informal gifting—though delays in declaration can carry risks.

Rules are set under Article 757 of the Code général des impôts and reinforced through administrative guidance.

Even informal gifts must be properly disclosed to avoid penalties. Planning ahead and understanding disclosure requirements is key for anyone giving or receiving manual gifts in France.

This episode helps listeners navigate one of France’s more nuanced gift-tax rules, balancing flexibility with compliance.

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 break down exactly when France can still tax the gift—and when it cannot.

🔎 What You’ll Learn in This Episode:

Where both parties are non-residents, France does not apply worldwide gift taxation.

➡️ The analysis turns entirely on where the asset is located.

French gift tax applies only to assets with a French situs, typically including:

• French real estate

• Certain movable assets located in France

In these cases, the gift may still fall within the French tax net, even though both parties live abroad.

If the gifted asset is located outside France:

• The gift falls entirely outside the French gift tax system

• No French gift tax applies

Residence alone is not enough—territorial connection is required.

This territorial limitation is expressly set out in Articles 750 ter and 757 of the Code général des impôts.

When both donor and donee are non-residents:

• French-situs asset → French gift tax may apply

• Foreign-situs asset → No French gift tax

Correctly identifying the location of the asset is therefore the decisive step.

This episode highlights a rare area of certainty in French gift taxation—showing how territorial limits apply cleanly when France has no personal tax connection to either party.

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 French residents to non-resident recipients—and why documentation still matters even when the tax scope is limited.

🔎 What You’ll Learn in This Episode:

When a French-resident donor makes a gift to a non-resident recipient, French gift tax applies only if the gifted asset is located in France.

➡️ France follows a territorial approach in this specific scenario.

Where French gift tax applies because the asset is located in France:

• The recipient (donee) is the taxable person

• The donor is not assessed for gift tax

This allocation reflects the structure of Articles 757 and 777 of the Code général des impôts.

Even though the donor is not taxed, they should ensure the gift is:

• Properly documented

• Formally executed (where required)

• Supported by clear valuation evidence

This is particularly important for high-value assets, where disputes may arise over the nature of the transfer or the value declared.

For gifts from French residents to non-residents:

• French-situs asset → French gift tax may apply (recipient pays)

• Foreign-situs asset → No French gift tax

• Strong documentation reduces risk, even when tax exposure is limited

This episode clarifies a commonly misunderstood corner of French gift taxation—helping families and advisors apply the rules accurately and avoid preventable disputes.

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 lives abroad, and why the recipient’s residence is decisive.

🔎 What You’ll Learn in This Episode:

Under Article 750 ter of the Code général des impôts, France taxes gifts on a worldwide basis when the recipient is fiscally domiciled in France.

➡️ Even if the donor is non-resident, the gift falls within the French tax net once the donee is resident in France.

In this scenario, where the asset is located does not matter.

French or foreign assets, cash or non-cash—all can be taxable when received by a French-resident donee.

France prioritizes personal connections (fiscal domicile of donor or recipient) over territoriality. This makes the system expansive and places significant weight on residence planning.

For cross-border gifts involving France:

• French-resident recipient → worldwide taxation risk

• Donor residence and asset location do not prevent taxation

Confirming the recipient’s fiscal domicile is therefore the first step in any French gift-tax analysis.

This episode clarifies why France’s gift-tax reach is among the broadest in Europe—and why international families must factor recipient residence into every gifting decision.