私人财富通讯-2025年第四版

Fourth Edition 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 ManagementPractice Group. We hope you find it an interesting read. 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 Loryand Sinéad McArdle, your commitment and resilience make this Newsletterpossible. We extend our sincere gratitude and thanks to you, and lookforward to our continued collaboration and friendship in 2026. Elliott MurrayManaging Editor, Geneva+ 41 22 707 98 39elliott.murray@bakermckenzie.com 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 politicalevents such as these are localised in their origin, the increasingly borderlessworld that global families inhabit means the impact of these developments ismore widespread in its reach. Phyllis TownsendCo-editor, London+ 44 20 7919 1360phyllis.townsend@bakermckenzie.com 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 countriesthat provide the political stability and personal security that families seekoften do so at the cost of higher tax burdens. 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, stronggovernance, and financial justification in considering whether setting up afamily office would be beneficial. 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 votershave historically rejected most redistributive and anti-wealth initiatives. Thearticle highlights that this sentiment among Swiss voters is part of the reasonwhy the country is considered a top destination for high-net-worth individualsand why it is likely to remain so. 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 anintergenerational asset. With effect from 6 April 2026, that relief will becapped. Alfie Turner and Pippa Goodfellow explore how family businesses canseek to mitigate or fund inheritance tax charges that they had neverpreviously anticipated paying. As always, our "Around the World" section helps us to stay up to date onrelevant and important cases and legislative developments, so we encourageyou to take a look. 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 orquestions. Until our next edition, we wish everyone an excellent year end andholiday season. Editors' note2 Articles Tax minimization vs. civil liberties:What matters most for global families?5 Navigating AI in private wealth10 When a Family Office is not the right fit:Three common pitfalls12 Swiss voters reject the “Initiative for the Future”:Direct democracy, stability, and the resilienceof the Swiss model15 The liquidity issue at the heart of the BusinessProperty Relief ("BPR") reforms: How do shareholdersin privately-owned businesses meet their unexpectedUK inheritance tax ("IHT") exposure? Around the world21 Wealth managementregional contacts24 Editorial contacts32 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 so