私人财富通讯-2025年第二版

Editors’ notePhyllis TownsendCo-editor, London+ 44 20 7919 1360Phyllis.Townsend@bakermckenzie.comElliott MurrayManaging Editor, Geneva+ 41 22 707 98 39Elliott.Murray@bakermckenzie.comOn behalf of Baker McKenzie’s Global Wealth Management &Alternative Capital Practice Groups, we are pleased to publish andpresent to our clients, friends, and colleagues the first edition in2025 of the Private Wealth Newsletter.The UK “res non-dom” regime has now come to an end with effect from6 April 2025, but this monumental change in the private client world hasbeen overshadowed by new global trade and tariff developments. Withthe backdrop of global trade disagreements, our lead article from MarninMichaels asks the question whether taxes, tariffs, and sanctions should bethought of as all part of the same “revenue generating” function ofgovernments and not independent subjects. If this premise is correct,what are the consequences for governments and their taxpayers?Turning to the Middle East and Asia, the current edition features updates onTaiwan’s CFC regime and related wealth management issues and on thedevelopments in the UAE pushing it to the forefront of wealth planningjurisdictions for private clients and family offices. In the UAE’s case, it figuresto be a bellwether for new regional planning hubs as its family foundationand trust offerings continue to increase in popularity and viability.For readers with interests in US and international tax planning for privateindividuals, closely-held businesses, and family offices, our PWN Meets seriesintroduces Robert (Bobby) Moore, a Tax Partner based in our Miami office.Bobby take us through his exciting practice, how he helps our clients, andwhat are the biggest risks he sees for private individuals and family officeswith cross-border issues.We hope you find something interesting, informative or thought-provokingin this edition, whether it be one of our feature articles or a piece from theAround the World section, compiling relevant and important cases, andlegislative developments from across the world.Our editors, Elliott Murray and Phyllis Townsend, or any of the authors listedthroughout the newsletter, can be contacted with any feedback or questions.Baker McKenzie Editors’ notePWN meets...ArticlesThe confluences of taxes, trade and tariffsTax developments impacting family wealthvehicles in the UAETaiwan:Asia Pacific Wealth Management– Recent developments and highlightsImplications of theVermilionSupreme Court decision for fund managersAround the worldWealth managementregional contactsEditorial contacts 24571014162028Baker McKenzieBaker McKenzie PWN meets...In the latest instalment of our series of interviews,Robert Moore talks to us about his experience of workingat the Firm and involvement in Wealth Management.Robert MoorePartner, MiamiPWNmeets...Baker McKenzie PLAY VIDEO The confluences of taxes,trade and tariffsAlmost 30 years ago I started my career, and I wanted to be a trust and estates lawyer. I even received an LL.M.in estate planning. For much of my career that meant a focus on tax related issues with smattering of trust andfoundation law, some regulatory issues and eventually an evolution into criminal tax related issues. However, theemphasis was on TAX.Approximately 15 years ago I noticed a global trend:whether correct or incorrect policy, governmentswere at the time pressured to reduce taxes, but at thevery same time finding greater sources of revenuebecause of increasing debt loads, an aging populationand unemployment amongst certain groups (in somecountries over 50% unemployment for people under theage of 30). At the exact same time, democratic statesbecame increasingly polarized, with the result thatelected officials from opposite side of the spectrumbecame less able/willing to cooperate with each other.Fast forward to 2022 and the Ukraine war: whileeventually many nation states provided economic andmilitary aid to Ukraine, the initial and concurrent attemptto weaken Russia was through sanctions. Unlike theproviding of funds or military weaponry which requiredlegislative action, sanctions could be executed byexecutive fiat.In this article I posit that in the last five years we haveseen three independent sources of law: (1) taxation; (2)tariffs; and (3) sanctions became one topic: revenuegeneration. We will explore the concept and specificallyhow each of the three are a form of revenue generationwith the latter, in effect, being a tax increase withoutthe public (voting public to be specific) appreciating thattariffs are, in effect, a form of value added taxation.Taxes, tariffs, and sanctions are different mechanismsemployed by governments to generate revenue andinfluence economic behavior. However, their convergenceinto a unified topic of revenue generation is a recentphenomenon driven by global economic pressures andpolitical dynamics.Article TaxesTaxes have been the primary tool for governments tocollect revenue. They come in various forms includinginco