CAPITAL FLOWS · MIDDLE EAST · CROSS-BORDER
The under-covered story in PIF's 2026-2030 strategy is not what the fund is cutting. It is what the fund is opening, and to whom.
Commentary on the matters,
markets, and jurisdictions
where we advise.
9 articles
9 articles
REGULATORY · STRUCTURING · SUCCESSION
The GRATs Act 2026 grantor trust provisions revoke Revenue Ruling 85-13. The $15M exemption OBBBA made permanent is worth less without the plumbing.
REGULATORY · FAMILY OFFICE · COMPLIANCE
UK mandatory tax adviser registration for family office principals goes live May 2026. The intra-group exemption is narrower than it reads.
REGULATORY · CROSS-BORDER · STRUCTURING
The UK carried interest 2026 territorial scope now reaches non-resident executives on any carry attributable to UK workdays. The rate is the distraction.
CROSS-BORDER · JURISDICTIONS · STRUCTURING · REGULATORY
The BFSA entered into force on 1 January 2026. Most families relocating from London to Zürich are capturing only half the benefit it was designed to deliver.
FAMILY OFFICE · FIDUCIARY · CAPITAL PLACEMENT
Families that allocated separately to private credit and private equity did not build a diversified alternatives sleeve. They built a concentrated bet on a single capital structure now showing strain on both ends.
REGULATORY · STRUCTURING · CROSS-BORDER
The UK carried interest reform April 2026 non-resident story is territorial, not arithmetic. A three-hour London meeting is now a UK income tax event.
LIQUIDITY EVENTS · M&A · REGULATORY
CBP's refund portal for $166 billion in unconstitutional IEEPA tariffs opened this morning. For family-owned importers, it is a capital decision.
REGULATORY · SUCCESSION · STRUCTURING
Division 296 and TD 2026/D1 are not separate tax changes. Together they are a single regime shift that penalises the Australian family office architecture of the last two decades.