MULTI
Curated migration intelligence for MULTI. 27 coverage pieces across residency, citizenship, and tax planning.
Canada departure tax: the deemed-disposition rules on emigration
For a Canadian resident who has built substantial wealth inside the country’s tax-sheltered structures, leaving is not a simple act of boarding a flight. The…
CRS (Common Reporting Standard): what HNW migrants should know in 2026
The Common Reporting Standard, or CRS, is not a new regime — it has been operational since 2017 across more than 110 jurisdictions — but a series of 2025-202…
Cyprus IP Box: how the effective 2.5% rate is computed in 2026
The Cyprus intellectual property box regime has been a fixture of European tax planning since its 2012 introduction, but a 2026-specific recalculation of the…
EU cross-border mobility for HNW residents: what your national residence permit does — and doesn't — buy you in 2026
A residence permit obtained in one EU member state, including one granted through Portugal's ARI, Malta's MPRP, or any other investment route, does not itself confer the right to live and work in a second EU country. This guide explains the two separate legal regimes at play, the EU long-term resident status that does exist, and what it means for a multi-jurisdiction European plan in 2026.
FATCA: US-person designation and the exit-tax trigger under section 877A
The decision to renounce United States citizenship or terminate long-term residency has shifted from a question of lifestyle to one of balance-sheet liabilit…
Greece non-dom (Article 5A): the EUR 100k annual lump-sum regime
The question of whether Greece’s Article 5A non-dom regime offers a superior alternative to the standard non-domiciled resident tax framework is no longer th…
Hong Kong unilateral tax credits for outbound HNW residents
The question of how Hong Kong’s territorial tax system interacts with foreign tax obligations has moved from a theoretical planning point to a live complianc…
Inheritance and succession across jurisdictions: a planning matrix
For a family with assets spread across three or more jurisdictions, succession is rarely governed by a single law. It is governed by a collision of regimes —…
Italy non-resident heir inheritance tax: the planning gap to manage
The Italian inheritance tax regime for non-resident heirs is not a single rate but a cascade of thresholds, relationship tiers, and asset-location rules that…
Malta non-domiciled residency: remittance-basis taxation in practice
When a high-net-worth individual relocates to Malta and elects the non-domiciled (non-dom) status, the tax outcome is not a discount but a different set of r…
Multi-family office regulatory landscape in 2026: jurisdiction-by-jurisdiction
The question of which jurisdiction offers the most stable regulatory environment for a multi-family office is no longer abstract for principals who manage co…
Centre-of-vital-interests under OECD Model Tax Convention Article 4
The OECD Model Tax Convention’s Article 4 tie-breaker rule was designed for an era when a single individual had a single home. That era is ending. For the hi…
OECD Pillar 2: implications for single-family offices and holding structures
The question is no longer whether a single-family office will be caught by the OECD’s Pillar 2 rules, but how quickly the existing structure must be restruct…
Pension portability across migration: a five-jurisdiction primer
The question of what happens to accumulated pension wealth when a high-net-worth individual changes tax residence has moved from a technical footnote to a ce…
Portugal NHR 2.0 (IFICI): scope, eligibility and the 10-year horizon
In the final quarter of 2025, Portugal’s Non-Habitual Tax Resident regime entered its second iteration — commonly referred to as NHR 2.0 or, by its statutory…
Pre-immigration tax planning: a 12-month roadmap before residency
The question of when pre-immigration tax planning should begin is usually answered with a single number: 12 months. This is not a rule of thumb but a functio…
Singapore territorial taxation and the foreign-sourced income relief
Singapore territorial taxation and the foreign-sourced income relief
Single-family office: Singapore vs Dubai vs Hong Kong vs Geneva compared
The decision to domicile a single-family office is, for most principals, a decision about regulatory architecture rather than lifestyle preference. Four juri…
Source vs residence tax conflict in dual-citizenship scenarios
The tax treatment of dual citizenship is rarely symmetrical, and the divergence between source-based and residence-based taxation creates a structural confli…
Substance requirements for offshore holding companies in 2026
The question of whether an offshore holding company possesses sufficient economic substance is no longer a niche compliance concern — it is a direct determin…
Switzerland lump-sum taxation: cantonal variation and 2026 floor
The question is no longer whether Switzerland’s lump-sum taxation regime will survive, but how advisors should navigate the widening gap between cantonal off…
Tax residency vs citizenship: a structural primer for migrating individuals
The distinction between tax residency and citizenship has become the single most consequential structural decision for internationally mobile high-net-worth…
Trust structures across jurisdictions: a comparison for migration planning
For a high-net-worth principal relocating cross-border, the choice of trust jurisdiction is not a tax afterthought — it is the structural foundation upon whi…
UAE 0% personal income tax: the substance requirements that bite
The UAE’s zero percent personal income tax regime is not a loophole; it is a statutory feature of Federal Decree-Law No. 47 of 2022 on the Taxation of Corpor…
UK non-dom abolition: the new four-year FIG regime explained
The repeal of the UK’s 226-year-old non-dom regime on 6 April 2025 was never going to be a clean cut, but the final architecture of its replacement — the fou…
UK Temporary Repatriation Facility (TRF): the three-year 12% window
The three-year, 12% rate on the UK’s Temporary Repatriation Facility (TRF) is the most consequential concession in the April 2025 non-domicile rule changes,…
US section 877A exit tax: covered-expatriate thresholds and gain calculation
The question of when a US citizen or long-term resident ceases to be a US person for tax purposes is rarely a matter of simple renunciation. Section 877A of…