Residence before structure
Until the principal’s domestic-law residence and treaty position are understood, a family office, trust, insurance or succession structure cannot be designed with confidence. For internationally mobile individuals and families, the fixed-fee CRS 2.0 Residence & Structuring Review provides a documented starting point.
Single-Family Offices (SFOs)
The priority is continuity across generations and regimes. Frameworks designed today must remain resilient to regulatory change and efficient for the families they serve.
Family office establishment is also supported end-to-end, in coordination with legal counsel, trustees and operational service providers.
Platform Establishment & Positioning
- SFO establishment, structuring and incentive regime positioning, including 13O and 13U.
- Residency, centre-of-gravity and substance narrative alignment.
- Pillar Two and minimum tax interaction with incentive frameworks.
Investment & Operational Efficiency
- Fund and investment vehicle structuring, rationalisation and tax efficiency.
- Cross-border investment and holding platform design.
- Withholding tax and treaty access optimisation across portfolio flows.
Long-Term Governance & Transition
- Succession architecture: generational transfer, family constitution alignment and estate planning coordination.
- Tax governance policy design and periodic tax function health checks.
- Transparency regime readiness: FATCA, CRS, CRS 2.0, CARF.
- Pre-liquidity and exit structuring for concentrated positions.
- Philanthropic vehicle design and tax-efficient giving frameworks.
Multi-Family Offices (MFOs)
The priority is institutional standardisation and scalable advisory infrastructure.
Client & Structuring Standards
- Client and entity classification policy design.
- Investment structuring standards and treaty access protocols across client portfolios.
- Operating model, documentation architecture and onboarding tax workflows.
Reporting & Risk Management
- Cross-client reporting, withholding tax recovery and reclaim processes.
- Transparency readiness frameworks and regulatory change management (FATCA, CRS, CRS 2.0, CARF).
- Risk heat-mapping across legacy structures.
Platform Governance
- Governance standardisation to manage friction and reputational exposure.
- Tax governance frameworks and board-facing tax reporting protocols.
- Platform-level Pillar Two assessment and incentive regime monitoring.
Principals & Private Clients
The priority is personal. Institutions carry reporting obligations. Exposure ultimately rests with individuals.
Residency & Structural Planning
- Residency planning, relocation structuring and TIN coverage validation.
- Holding structures requiring refresh for substance, anti-avoidance or efficiency reasons.
- Pre-transaction and liquidity event structuring.
Portfolio & Cross-Border Alignment
- Digital asset and alternative investment exposure intersecting with emerging regulatory regimes.
- Family office platform coherence across tax, governance and succession.
- Cross-border employment, compensation and equity participation arrangements.
- Philanthropic intent requiring tax-efficient and jurisdictionally sound structuring.
Discretion and clarity remain central.