Digital nomads once thrived in the gaps between tax systems. Built around physical presence and permanent residence, traditional tax rules struggled to keep up with a workforce that could earn globally while living temporarily almost anywhere. That era is ending.

In this episode, we explore why governments are now actively targeting digital nomads—and how the regulatory “gray zone” is being closed.

Traditional tax systems assume work is performed in a specific country.

Digital nomads often work entirely online, with no physical office and no clear “place of work.”

Nomads may:

• Earn income from clients in one country

• Hold bank accounts in another

• Live temporarily in a third

This fragmentation made it difficult for any single jurisdiction to assert taxing rights.

Through tourist visas or newer digital nomad visas (DNVs), individuals could remain in a country for extended periods while technically avoiding tax residence—sometimes for years.

The result was a regulatory blind spot where income often went untaxed.

Governments are no longer tolerating this ambiguity. Instead, they are:

• Tightening tax residency rules and “center-of-life” tests

• Linking visa regimes more closely to tax compliance

• Expanding definitions of source and personal income

• Increasing information sharing between tax authorities

• Scrutinising lifestyle, presence, and economic substance—not just formal status

What was once informality is now being reframed as non-compliance.

The digital nomad “gray zone” is closing fast.

For individuals:

• Low-tax outcomes based on mobility alone are becoming harder to sustain

• Tax exposure increasingly follows presence, benefit, and economic reality

For governments:

• Mobile workers represent a reclaimable tax base

• Digital nomad regimes are shifting from attraction tools to compliance gateways

Digital mobility is no longer invisible—and tax planning based on ambiguity is rapidly becoming obsolete.

Tax authorities around the world are quietly—but decisively—redefining what counts as private income. In this episode, we explore how governments are moving beyond traditional notions of salary and wages toward broader “economic substance” frameworks designed to capture income generated through modern wealth structures.

This evolution reflects deep structural changes in how wealth is created, held, and monetised in a globalised and digital economy.

Historically, private income was closely associated with employment income. That model is increasingly outdated.

Tax authorities are now focusing on economic reality, not labels—asking where value is created, who controls it, and who ultimately benefits.

Expanded definitions of private income increasingly encompass:

• Digital assets (including crypto-related income and digital platforms)

• Rental and property income, including short-term and cross-border arrangements

• Private investment vehicles, family holding companies, and SPVs

• Distributed or retained income within closely held structures

Income that once sat outside clear tax categories is now being systematically brought into scope.

Family offices, trusts, foundations, and layered corporate structures are receiving greater attention—particularly where income is:

• Accumulated rather than distributed

• Recharacterised as capital rather than income

• Allocated across jurisdictions

The focus has shifted from formal ownership to control, benefit, and access.

This expanded approach has significant implications:

• Individuals may be taxed on income they did not previously regard as “personal”

• Passive or deferred income may no longer escape current taxation

• Substance, transparency, and documentation are becoming critical

• Long-standing planning assumptions are being reassessed by authorities

The definition of private income is no longer static. As tax systems adapt to modern wealth, income is being redefined to follow economic substance, not form.

For high-net-worth individuals, families, and advisors, this means:

• Broader tax exposure

• Increased reporting obligations

• The need for proactive, integrated planning

What once sat in grey areas is now moving firmly into the tax base.

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, we explore how real estate–linked wealth and gift taxes are reshaping succession planning, professional advisory work, and global competition between jurisdictions.

The era of effortless dynastic wealth transfer is over.

Succession planning involving real estate is now:

• More complex — crossing tax, civil law, and regulatory systems

• More expensive — valuation, compliance, and liquidity planning are unavoidable

• More long-term — planning horizons are measured in decades, not years

Families must increasingly confront difficult questions around:

• Control and governance

• Liquidity to fund future tax liabilities

• Timing of transfers

• Inter-generational alignment

Real estate, once seen as a “safe” asset to pass down, now demands active, ongoing planning.

Demand for sophisticated cross-border estate planning is accelerating rapidly.

The advisor’s role has evolved from:

➡️ Pure tax minimisation

to

➡️ Holistic risk management

This includes:

• Navigating expanding reporting and transparency regimes

• Ensuring liquidity for wealth, inheritance, or gift taxes

• Coordinating tax law with succession, governance, and family dynamics

• Structuring assets to withstand legal, regulatory, and family challenges

Advisors are now expected to act as strategic architects, not just technical specialists.

A new form of competition is emerging between countries.

While some jurisdictions debate or introduce higher wealth-related taxes—such as proposals in the United States or discussions in the United Kingdom—others are actively positioning themselves as “Wealth Preservation Hubs.”

Examples include:

• Singapore and Switzerland, which do not levy inheritance tax on certain foreign assets or non-resident families

• Italy, with its flat-tax regime for new residents

• The United States, which—despite a high federal estate tax—remains attractive due to strong legal certainty and dynasty trust regimes in states such as South Dakota and Nevada

Capital is increasingly mobile, and jurisdictions are competing not just on tax rates, but on legal stability, planning flexibility, and long-term certainty.

Wealth and gift taxes on real estate are no longer niche concerns—they are structural features of modern fiscal policy.

• Families must plan earlier, deeper, and more collaboratively

• Advisors must integrate tax, law, liquidity, and governance

• Jurisdictions are competing for mobile wealth through legal design, not secrecy

The common thread: real estate wealth now requires strategy, not assumption.

After decades of retreat, wealth taxes are making a comeback. Once common across advanced economies, net wealth taxes nearly disappeared by 2020—surviving in only a handful of countries. Today, however, shifting political priorities, fiscal pressure, and rising inequality are driving a renewed global debate.

This episode explores why wealth taxes are returning, how they are being redesigned, and what the evidence says about their impact.

Wealth taxes—direct levies on an individual’s net assets—peaked in the 1990s, when 12 OECD countries applied them. By 2020, only Norway, Spain, and Switzerland retained a net wealth tax.

That period of decline is now ending. Policymakers are again viewing wealth taxation as a viable—and politically salient—tool.

Economic modelling suggests that a 4% “Wealth Proceeds Tax” could raise more than USD 45 billion annually for U.S. state governments—highlighting why the concept has regained traction.

Recent U.S. federal proposals include:

• A 25% minimum tax on unrealised gains

• Targeted at individuals with net wealth above USD 100 million

This represents a significant conceptual shift away from realisation-based taxation.

At the sub-national level, several U.S. states are considering “millionaire taxes”, typically structured as:

• Income surtaxes

• Applied to earnings above high-income thresholds

While not classic wealth taxes, they reflect the same policy objective: greater taxation of top wealth holders.

Critics argue that wealth taxes:

• May discourage investment and entrepreneurship

• Are costly and complex to administer

• Often raise less revenue than projected once avoidance, valuation issues, and behavioral responses are factored in

These concerns contributed to their earlier repeal in many countries.

Supporters counter that wealth taxation is necessary to:

• Sustain public finances

• Reduce reliance on labor and consumption taxes

• Address the political and economic power associated with extreme wealth concentration

From this perspective, wealth taxes are framed as tools of democratic balance, not just revenue collection.

The return of wealth taxes signals one of the most consequential shifts in modern fiscal policy. Whether through net wealth taxes, unrealised gains, or high-income surtaxes, governments are clearly moving toward greater scrutiny of accumulated wealth.

For high-net-worth individuals and advisors, the direction of travel is unmistakable:

wealth—not just income—is back on the tax agenda.

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.