私人财富通讯-2025年第四版

Editors’ note As we enter the festive season, we are delighted to releaseour last edition of the year of the Private Wealth Newsletteron behalf of Baker McKenzie's Global Wealth Management With the year-end approaching, we would like to take this opportunity tothank our valued clients and other readers for their continued support andengagement. We wish you all the best for the holiday season as well ascontinued health, success, and prosperity in the New Year. To our colleagues,from the contributing authors to our production team led by Laetitia Lory Elliott MurrayManaging Editor, Geneva+ 41 22 707 98 39elliott.murray October and November 2025 were important months in the US, European andglobal private client world. Speculation and headlines surrounded the electionof Mayor Zohran Mamdani in New York on 4 November and also preceded theUK Labour Government’s second Budget on 26 November. While political Phyllis TownsendCo-editor, London+ 44 20 7919 1360 Our first feature from Marnin Michaels is a careful consideration of twoconflicting key factors, both of which tend to drive global families' decisionsto relocate: tax minimisation and civil liberties. It delves into how countries In our second feature, Rachael Cederwall analyses how the rapid growth andexpansion in artificial intelligence (AI) is impacting the trust and fiduciarysector. The article looks at the benefits and risks that AI poses to the sector. In our third feature, Jacopo Crivellaro considers the lesser-explored pitfalls thatcan plague family offices and cautions that a family office is not suitable in allinstances. The article highlights the need for focused long-term vision, strong Our next article moves to Switzerland to focus on the referendum that tookplace on 30 November concerning whether there should be a tax on ultra-highnet worth families. Sylvain Godinet writes about the Swiss voters' rejection ofthe "Initiative for the Future", which proposed a federal inheritance and gifttax of 50% on estates and donations exceeding CHF 50 million. Swiss voters Our final feature considers the recent changes to the UK inheritance taxlandscape, and in particular how these changes will impact on familybusinesses. Currently there is 100% relief from UK inheritance tax for certaintypes of privately-owned trading businesses. Many family-owned businessesrely on this relief to ensure that the business can be passed down as an As always, our "Around the World" section helps us to stay up to date onrelevant and important cases and legislative developments, so we encourage We hope you find something interesting, informative, or thought-provoking inthis edition. You can contact our editors, Elliott Murray and Phyllis Townsend,or any of the authors listed throughout the newsletter with any feedback or Editors' note ArticlesTax minimization vs. civil liberties:What matters most for global families? Navigating AI in private wealth When a Family Office is not the right fit:Three common pitfalls Swiss voters reject the “Initiative for the Future”:Direct democracy, stability, and the resilience The liquidity issue at the heart of the BusinessProperty Relief ("BPR") reforms: How do shareholdersin privately-owned businesses meet their unexpected Around the world Wealth managementregional contacts Editorial contacts Tax minimization vs. civil liberties:What matters most for global families? The surge in wealth tax proposals and implementationsacross jurisdictions reflects a broader shift in howgovernments approach fiscal policy and social equity.While countries like Argentina, Belgium and Switzerlandhave long-standing wealth taxes, recent moves byCalifornia and other regions signal a growing willingness Introduction Global families are struggling with tax changes takingplace throughout the world, prompting many to relocate.As many locations make themselves less attractivefor global families, some are working to become moreattractive. For example, the UK has made it significantlyless appealing for certain wealth owners to live therefrom a tax perspective (while attracting newcomersand returners who have been outside the UK for 10years under its new regime). At the same time, many One key challenge is the lack of harmonization in taxregimes. Thresholds, rates and definitions of taxableassets vary widely, creating planning difficulties for Political instability and rapid policy shifts add anotherlayer of uncertainty. The pendulum of political changecan quickly alter tax laws, tariffs and sanctions,impacting wealth preservation strategies. Families must The landscape of tax minimization for UHNWIs Global trends in wealth taxation Recent years have seen a surge in proposals andimplementations of wealth taxes across jurisdictions.Countries such as Argentina, Belgium, Bolivia, Colombia,France, Italy, Norway, Spain, Switzerland, Uruguay andVenezuela have enacted various forms of net wealth taxes,with rates and thresholds tailored to capture the ass