Shows / Offshore Tax with HTJ.tax
Offshore Tax with HTJ.tax
- Updated daily, we help 6, 7 and 8 figure International Entrepreneurs, Expats, Digital Nomads and Investors legally minimize their global tax burden and protect their wealth. - Join Amazon best selling author, Derren Joseph, in exploring the offshore financial world. Visit www.htj.tax
Episodes
- Offshore Tax with HTJ.tax
How France Taxes US Dividends and Capital Gains
If you are a French tax resident holding U.S. investments, your returns are not just subject to U.S. tax rules—they fall squarely within the French worldwide…
- Offshore Tax with HTJ.tax
Timing of US Deferred Compensation After Moving to France
When U.S. deferred compensation is paid after you become a French tax resident, timing becomes critical. The interaction between U.S. taxation and French…
- Offshore Tax with HTJ.tax
Avoiding Double Tax Between the US and France
When income is taxed in both the United States and France, the solution is not exemption—it’s coordination. In this episode, we explain how the foreign tax…
- Offshore Tax with HTJ.tax
US 409A Deferred Compensation & French Tax Residency
Cross-border executives often assume deferred compensation is taxed where it was earned. Under U.S. Section 409A, that assumption can be costly once you become…
- Offshore Tax with HTJ.tax
Moving Funds Out of China - Privately
China’s 2018 ODI reforms (Order No. 11) strengthened supervision of outbound investments. In this episode, we clarify what investors must do before, during…
- Offshore Tax with HTJ.tax
China’s Restricted ODI Investments
China’s Outbound Direct Investment (ODI) regime does not only classify projects as “encouraged” or “prohibited.” A significant middle category exists…
- Offshore Tax with HTJ.tax
China’s Prohibited ODI Investments
While China encourages strategic outbound investment, certain categories are strictly prohibited. Projects that threaten national interests or national…
- Offshore Tax with HTJ.tax
ODI Projects the Government Supports
China’s Outbound Direct Investment (ODI) policy is not neutral—it is strategically guided. Certain categories of overseas investment are actively encouraged…
- Offshore Tax with HTJ.tax
China’s 2018 ODI Rule Changes
In March 2018, China introduced significant reforms to its Outbound Direct Investment (ODI) regime. These changes—implemented through Order No. 11—expanded…
- Offshore Tax with HTJ.tax
China’s Outbound Investment Rules
China’s Outbound Direct Investment (ODI) regime has evolved from strict pre-approval controls to a more structured, risk-based regulatory system. In this…
- Offshore Tax with HTJ.tax
ODI and Wealth Management Opportunities
China’s Outward Direct Investment (ODI) regime channels substantial capital abroad each year. For global wealth managers, trustees, funds, and private banks…
- Offshore Tax with HTJ.tax
What Is China’s ODI Initiative?
China’s Outward Direct Investment (ODI) strategy operates on two parallel tracks: large-scale state-backed projects under the Belt and Road Initiative (BRI)…
- Offshore Tax with HTJ.tax
Hong Kong vs Switzerland: Look-Through Rules for Trust Equity Interests
This episode explores how different jurisdictions interpret the CRS look-through rules for trusts that qualify as Reporting Financial Institutions…
- Offshore Tax with HTJ.tax
OECD CRS FAQ On Equity Interest Of A Financial Institution Held By A Financial Institution
This episode looks at an often-cited but rarely analysed source: the OECD CRS FAQ on General Reporting Requirements, specifically Page 2, Question 7, dealing…
- Offshore Tax with HTJ.tax
CRS Commentary on Financial Institutions Holding Equity Interests
This episode examines a pivotal provision in the CRS Commentary—paragraph 178 (Section VIII, C(4))—and its implications for trusts that qualify as Reporting…
- Offshore Tax with HTJ.tax
CRS Treatment of Financial Institutions as Equity Interest Holders
This episode examines a core structural rule of the Common Reporting Standard (CRS): Financial Institutions are non-reportable persons and must not be looked…
- Offshore Tax with HTJ.tax
Where Switzerland Misinterpreted the CRS Implementation Handbook
This episode examines a narrow but consequential interpretative issue: Did Switzerland extend the CRS look-through rules for FI-trusts beyond what the OECD…
- Offshore Tax with HTJ.tax
The Core CRS / FATCA Principle: No Look-Through of Financial Institutions
The Core CRS / FATCA Principle: No Look-Through of Financial InstitutionsAt the heart of both CRS and FATCA lies a fundamental architectural rule: Financial…
- Offshore Tax with HTJ.tax
How Switzerland Misapplied CRS Look-Through Rules for Trusts
In this episode, we examine a controversial development in Swiss CRS practice: the extension of look-through obligations for trusts that qualify as Reporting…
- Offshore Tax with HTJ.tax
Who Is An Equity Interest Holder Of A Trust Qualifying As A Reporting FI
Understanding who counts as an equity interest holder is central to how the Common Reporting Standard (CRS) operates for trusts that qualify as Reporting…
- Offshore Tax with HTJ.tax
When Absence Doesn’t Break Residency
Leaving a country does not automatically mean you stop being a tax resident. In this episode, we explain why tax residency is a legal status, not a travel…
- Offshore Tax with HTJ.tax
Advice for Tax Advisors Going Forward
As global tax enforcement intensifies and private wealth comes under greater scrutiny, the role of the tax advisor is evolving fast. In this episode, we…
- Offshore Tax with HTJ.tax
Advising High-Net-Worth Individuals
As global tax policy shifts toward greater scrutiny of private wealth, advising high-net-worth individuals with international assets requires a fundamentally…
- Offshore Tax with HTJ.tax
The Future of Taxation's Pillar Three
Beyond Pillar One and Pillar Two, a new concept is beginning to surface in global tax policy discussions: an informal “Pillar Three”—focused not on…
- Offshore Tax with HTJ.tax
The Expanding Definition of Private Income
Digital nomads once thrived in the gaps between tax systems. Built around physical presence and permanent residence, traditional tax rules struggled to keep up…
- Offshore Tax with HTJ.tax
The Expanding Definition of Private Income
Tax authorities around the world are quietly—but decisively—redefining what counts as private income. In this episode, we explore how governments are moving…
- Offshore Tax with HTJ.tax
Wealth or Gift Taxes on Real Estate
Real estate is increasingly at the center of wealth and gift taxation debates—and the implications reach far beyond tax rates alone. In this episode, we…
- Offshore Tax with HTJ.tax
The Return of Wealth Taxes
After decades of retreat, wealth taxes are making a comeback. Once common across advanced economies, net wealth taxes nearly disappeared by 2020—surviving in…
- Offshore Tax with HTJ.tax
The Global Shift Toward Private Wealth Taxation
A profound shift is underway in global fiscal policy. After decades of declining emphasis on wealth taxes, governments are renewing and intensifying their…
- Offshore Tax with HTJ.tax
Pillar One and Pillar Two Explained
The OECD’s Pillar One and Pillar Two reforms represent the most significant overhaul of international corporate taxation in decades. In this episode, we…
- Offshore Tax with HTJ.tax
What Is The Main Risk In Cross-Border Gift Planning?
In cross-border gift planning, the biggest mistakes rarely come from complex law—they come from misalignment. In this episode, we explain why the most…
- Offshore Tax with HTJ.tax
Can The Same Gift Be Taxed In More Than One Country?
Yes—and this is one of the most common (and misunderstood) risks in cross-border gifting. In this episode, we explain how and why double taxation can arise on…
- Offshore Tax with HTJ.tax
French Gift Tax Rules For Donations Manuelles
Not all gifts are created equal under French law. In this episode, we explain how informal or manual gifts—called donations manuelles—are treated for French…
- Offshore Tax with HTJ.tax
What Happens In France When Both Donor And Donee Are Non-Residents?
When neither the donor nor the recipient is fiscally domiciled in France, French gift tax applies on a strictly territorial basis. In this episode, we break…
- Offshore Tax with HTJ.tax
When Does French Gift Tax Apply To Gifts From Residents To Non-Residents?
French gift tax rules change depending on who is resident and where the asset is located. In this episode, we explain when France taxes gifts made by French…
- Offshore Tax with HTJ.tax
Are Gifts From Non-Residents Taxable When The Recipient Is French Resident?
Yes—and this often catches families by surprise. In this episode, we explain why France can tax a gift on a worldwide basis even when the donor lives abroad…
- Offshore Tax with HTJ.tax
Does France Tax Gifts On A Worldwide Basis?
France takes a markedly different approach to gift taxation compared with many other countries. In this episode, we explain when France taxes gifts on a…
- Offshore Tax with HTJ.tax
What Happens In Portugal When Both Donor And Donee Are Non-Residents?
A common misconception is that Portugal only taxes gifts when one of the parties lives there. In this episode, we explain what actually matters when both the…
- Offshore Tax with HTJ.tax
Is Stamp Duty Due When A Portuguese Resident Gives A Gift To A Non-Resident?
When a Portuguese resident makes a gift to someone living abroad, a common question arises: does Portugal charge Stamp Duty because the donor is resident? In…
- Offshore Tax with HTJ.tax
When Does Stamp Duty Apply To Gifts From Non-Residents In Portugal?
Gifts involving non-residents often raise a key question: does Portugal tax the gift because the recipient lives there? In this episode, we clarify when…
- Offshore Tax with HTJ.tax
Are Family Gifts Always Reportable In Portugal?
Family gifts in Portugal are often tax-free—but are they always reportable? In this episode, we explain the important clarification introduced by Portugal’s…
- Offshore Tax with HTJ.tax
Are Gifts Between Close Family Members Taxed In Portugal?
Portugal’s approach to family gifts is often misunderstood. In this episode, we explain when gifts between family members are completely tax-free—and why the…
- Offshore Tax with HTJ.tax
Who Is Taxed On A Gift In Portugal?
When making or receiving a gift in Portugal, a common question is who actually pays the tax. In this episode, we explain how Portuguese law allocates the tax…
- Offshore Tax with HTJ.tax
Does Portugal Have A Gift Tax?
Portugal is often described as having “no gift tax”—but that statement needs context. In this episode, we explain how gifts are actually taxed in Portugal, why…
- Offshore Tax with HTJ.tax
Can Non-Residents Benefit From Regional ISD Reductions In Spain?
Spanish Inheritance and Gift Tax (ISD) is heavily influenced by regional tax benefits, but for years those benefits were largely denied to non-residents. In…
- Offshore Tax with HTJ.tax
Gift Tax In Spain When Both Donor And Donee Are Non-Residents
What happens when neither the donor nor the recipient is resident in Spain—but the gifted asset is located there? In this episode, we explain when Spanish Gift…
- Offshore Tax with HTJ.tax
Is A Spanish Donor Taxed When Giving A Gift To A Non-Resident?
A frequent point of confusion in cross-border gifting is whether a Spanish-resident donor becomes liable to Spanish gift tax when making a gift to a…
- Offshore Tax with HTJ.tax
Gifts From Abroad: Spanish Tax Implications
When gifts cross borders, Spanish gift tax rules can quickly become complex. In this episode, we explain when Spanish Gift and Inheritance Tax (ISD) applies to…
- Offshore Tax with HTJ.tax
Does Spain Tax Gifts On A Worldwide Basis?
Gift taxation in Spain depends on who receives the gift and where they are tax resident. In this episode, we clarify when Spain applies gift tax on a worldwide…
- Offshore Tax with HTJ.tax
Gift Taxation in Spain, Portugal & France
Gift taxation across Europe often creates confusion—especially in cross-border situations. In this episode, we unpack how Spain, Portugal, and France approach…
- Offshore Tax with HTJ.tax
Why Custodial Institutions Are Not Look-Through Entities
Automatic Exchange of Information (AEOI) under CRS/FATCA is highly structured and tiered. It is designed to allocate reporting once—not duplicate it. Yet a…
- Offshore Tax with HTJ.tax
Custodial Institution Settles a Cook Islands Trust
Can a custodial institution legally settle a Cook Islands trust—and what does that mean for FATCA and CRS reporting? In this episode, we walk through the…
- Offshore Tax with HTJ.tax
A Superior Structure to the Cook Islands Trust?
From time to time, structures are presented as being “stronger” or “more private” than a traditional Cook Islands trust. In this episode, we critically examine…
- Offshore Tax with HTJ.tax
Why Cook Islands Trusts Can Be Unsuccessful in U.S. Courts
Cook Islands trusts are often described as legally robust under offshore law—yet some have still ended badly for settlors in U.S. courts. In this episode, we…
- Offshore Tax with HTJ.tax
Contempt of Court Cases and Cook Islands Trusts
Cook Islands trusts are often marketed as impenetrable asset-protection tools—but U.S. court records tell a more nuanced story. In this episode, we examine why…
- Offshore Tax with HTJ.tax
Criticisms of Cook Islands Trusts
Cook Islands trusts are frequently presented as the strongest form of asset protection available—but they are not immune from criticism or regulatory reality…
- Offshore Tax with HTJ.tax
How Cook Islands Trusts Protect Assets Like a Fortress
Cook Islands trusts are often described as the “fortress” of asset protection—but what does that really mean in legal terms? In this episode, we break down the…
- Offshore Tax with HTJ.tax
Limitations of the Cook Islands Trust
Cook Islands trusts are powerful asset-protection tools, but they are not magic shields. In this episode, we take a clear-eyed look at the limitations of Cook…
- Offshore Tax with HTJ.tax
Who Typically Uses a Cook Islands Trust
Cook Islands trusts are not one-size-fits-all solutions. They are typically used by individuals who face elevated legal, professional, or commercial risk and…
- Offshore Tax with HTJ.tax
Cook Islands Trust: Core Asset Protection Features
Cook Islands trusts are widely regarded as one of the most robust asset-protection vehicles in the world—but why? In this episode, we break down the core legal…