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Brazilian-source income, ITCMD on Brazilian-sited assets, and the planning most expatriates have not done. There is a recognisable Brazilian expatriate. The executive who built a São Paulo business and moved to Lisbon, Madrid, Miami, or Dubai. The entrepreneur who sold a Brazilian operating company and now lives, on the proceeds, between Switzerland and the United States. The next-generation heir who studied abroad, never went home, and inherited a Brazilian portfolio they have not yet had time to think about. The common feature is that the move out of Brazil was, for personal income tax purposes, complete: the Declaração de Saída Definitiva was filed; the Brazilian fiscal year closed; worldwide income is now taxed in the country of new residency, not

What Law 14,754/2023 changed, what the Supreme Court just confirmed about VGBL, and what it all means for offshore PPLI held by Brazilian residents. On 1 January 2024, the rule book that governs offshore wealth for Brazilian tax residents was rewritten. Law 14,754/2023, signed by President Lula in December 2023, ended decades of deferral. Financial investments abroad now attract a flat 15% Brazilian income tax. Profits of offshore companies controlled by Brazilian individuals are taxed annually, whether distributed or not. Foreign trusts are tax-transparent — assets treated as belonging to the settlor, income taxed as it arises. The structures that quietly worked for a generation of Brazilian families — Cayman holdings, BVI nominee companies, Bahamas trusts — are no longer

Singapore’s tax system stops following you the day you stop being resident. The tax systems of the places you go to — and the places your assets sit — do not. Consider another engagement. A Singapore-resident HNW client built and sold a business in Singapore over twelve years, then relocated his family to London in 2025. He kept a S$8 million Singapore brokerage account, his Singapore residential property (now leased), and a 12% interest in an Indonesian operating company that the original sale didn’t include. He thought, reasonably enough, that by ceasing to be Singapore tax resident he had cleared his international tax decks. He had not. Singapore does indeed stop taxing his foreign-sourced income on the day he ceases

Why offshore PPLI is one of the most useful planning tools in Asia — and the one most often mis-sold to Singapore-resident clients. Consider a recent client engagement. A Singapore-resident HNW investor who relocated from London four years ago runs a regional advisory business, holds a USD 6 million portfolio at a Singapore private bank, owns an apartment in District 10 in her own name, and has two children — one of whom now lives in Tokyo. Her wealth manager had recommended an offshore Private Placement Life Insurance policy. She came to us for a second opinion. The pitch she had been given was the standard one. Wrap your portfolio inside a Luxembourg life insurance policy and your investments compound

You sold your Australian business and moved to Dubai. The ATO stopped following you — mostly. Here is what it still taxes, and where PPLI changes the picture. There is a common, comfortable assumption among Australians who leave. The moment the residency status flips — the airline ticket, the Australian Taxation Office’s residency questionnaire, the closing of the Medicare card — the ATO falls away. Worldwide income tax becomes Australian-source income tax. Worldwide CGT becomes CGT on a narrow class of assets. For most former residents, that intuition is roughly correct. The Australian tax base contracts dramatically on departure. But it does not contract to zero. Division 855 of the Income Tax Assessment Act 1997 confines a non-resident’s CGT exposure

Australia’s 50% CGT discount is one of the world’s most generous investment tax concessions. PPLI does not replicate it. But for the right client, it does something the CGT discount cannot. Start with a sentence I would not have written before 2010: PPLI is now meaningfully usable for Australian tax residents. The Foreign Investment Fund (FIF) rules — the historical reason advisers in this market kept offshore life policies at arm’s length — were repealed by the Tax Laws Amendment (Foreign Source Income Deferral) Act (No. 1) 2010, replaced by a much narrower anti-roll-up regime that targets debt-heavy passive entities rather than diversified investment-linked life policies. The practical effect is that for an Australian-resident client, the question of holding offshore

The US takes 30% of every dividend paid to non-US investors. PPLI can reduce that — but the outcome depends on where your policy is issued, and for some clients it makes things worse. Here is the honest analysis. You hold a portfolio of US stocks. You reinvest the dividends. Every quarter, before a cent reaches your account, the US government takes 30 cents in every dollar of dividend income. This is US withholding tax — specifically, the 30% tax the United States imposes on Fixed or Determinable Annual or Periodical (FDAP) income paid to non-US investors. Dividends from US corporations are FDAP income. For a non-resident alien (NRA) holding USD 3 million in US equities at a 2% annual