Offshore Tax with HTJ.tax

Top Company (Custodial Institution)

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• The company’s articles and memorandum allow its shares to transfer automatically to designated third parties (typically family members) upon the shareholder’s death.
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• This mechanism does not create a trust, because there is no fiduciary relationship—only a custodial structure.
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• Therefore, it does not fall under EU trust-related sanctions, which target fiduciary and ...

While custodians and fiduciaries are closely related, they serve fundamentally different roles in wealth management and trust structures. Importantly: all fiduciaries are custodians in some sense, but not all custodians are fiduciaries.

1. Custodial Institution (“Vault Keeper”)

Role: Safeguard and protect client assets.

Core Function: Holding assets securely against loss, theft, or error.

Key Responsibiliti...

In this episode, we break down the EU’s crackdown on Russian-linked trusts — now widely referred to as “zombie trusts” — following amendments to Article 5m of Council Regulation (EU) 833/2014. These rules have rendered many existing structures legally unserviceable and have effectively shut the door to new trust formation involving Russian nationals or entities.

Key Points Covered:

1. What Article 5m Now Prohibits

Under t...

In this episode, we explore how wealthy Russians are responding to the tightening global network of financial transparency — particularly the Common Reporting Standard (CRS) and the Automatic Exchange of Information (AEOI). These frameworks have dramatically reduced financial secrecy, forcing individuals to adapt quickly or risk exposure to Russian tax authorities and enforcement actions.

Key Discussion Points:

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3. Formal...

We examine why many wealthy Russians are especially worried about global information-exchange regimes. The Common Reporting Standard (AEOI/CRS) and Exchange-on-Request (EoR) create layered visibility that can expose residency, assets, and financial flows — with consequences ranging from tax assessments to targeted investigations. Host countries that once offered anonymity now participate in automatic reporting, and requests from fo...

In this episode, we explore how certain jurisdictions remain outside the reach of CARF (Crypto-Asset Reporting Framework) — and why Svalbard and UK non-resident trusts continue to offer unique confidentiality advantages.

Key Insights:

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• Svalbard’s Unique Legal Shield
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• Under Article 8 of the 1925 Treaty of Svalbard, no signatory nation may receive tax benefits or preferential treatment related to Svalbard a...

In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

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• RCASP Defined:
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• A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
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• Entities Typically Considered RCASPs:
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In this episode, we explain who must report under the Crypto-Asset Reporting Framework (CARF) — and why understanding your role is critical for compliance.

Key Takeaways:

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• RCASP Defined:
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• A Reporting Crypto-Asset Service Provider (RCASP) is any individual or entity that enables or carries out crypto exchange transactions on behalf of clients as a business.
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• Entities Typically Considered RCASPs:
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In this episode, we break down when crypto transactions become reportable under the Crypto-Asset Reporting Framework (CARF) — and why not every wallet movement or exchange triggers a filing.

Key Takeaways:

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• Spending Crypto Triggers Reporting:
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• Direct purchases of goods or services with crypto remain rare. Most users must convert crypto into fiat before spending — and that’s often where reporting begins.
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• Ac...

In this episode, we unpack how the Crypto-Asset Reporting Framework (CARF) differs from its predecessors — FATCA and CRS — and why these differences matter for compliance and reporting transparency in the crypto era.

Key Takeaways:

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• Transaction-Based Reporting:
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• Unlike FATCA and CRS, which focus on income and asset values, CARF requires Reporting Crypto-Asset Service Providers (RCASPs) to disclose transactions made b...

The Crypto-Asset Reporting Framework (CARF) is designed to bring order, oversight, and accountability to the fast-moving world of digital assets. Its goals align closely with global efforts to prevent tax evasion, money laundering, and the misuse of crypto for illicit activity.

Key Objectives:

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• Increase Transparency — Shine a light on crypto asset holdings and transactions to help authorities track the flow of funds ac...

The Crypto-Asset Reporting Framework (CARF) represents the next major evolution in global financial transparency. It builds upon a lineage that started with FATCA, evolved through the Common Reporting Standard (CRS), and now extends to the world of digital assets.

The Evolution:

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• FATCA (Foreign Account Tax Compliance Act) — Launched by the U.S., FATCA was the original model for cross-border reporting. It forced non-U.S...

For many expats and entrepreneurs, maintaining or managing a foreign company while living in Portugal seems straightforward — but Portugal’s corporate tax rules can make things more complex than expected.

Key Point:

Unlike some countries that rely heavily on the “Place of Effective Management” (POEM) as a tie-breaker rule, Portugal uses “effective management” as a primary test for determining corporate tax residency.

Here’s what t...

If you’re planning to live, work, or even spend extended time in Portugal, there’s one acronym you’ll hear again and again — NIF.

What Is a NIF?

The NIF (Número de Identificação Fiscal) is your personal tax identification number — a nine-digit code issued by the Portuguese Tax Authority (Autoridade Tributária e Aduaneira). Think of it as your financial identity in Portugal.

Who Needs a NIF?

It’s not just for taxpayers or reside...

It’s easier than many people think to become a tax resident in Portugal by accident — and the consequences can be significant.

What Happens If You Accidentally Become a Resident:

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• 💰 Worldwide Taxation: You’ll be taxed on all your global income — salaries, pensions, investments, and rental income.
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• 🧾 Annual Filing Required: You must file a Portuguese tax return each year, even if most of your income is earne...

Portugal offers a unique incentive to encourage talented professionals to return home — but it’s not widely known outside the tax and legal community.

The Opportunity:

If you’ve been living abroad and decide to re-establish tax residency in Portugal, you may qualify for a 50% income tax deduction for five years.

How It Works:

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• 🕒 Eligibility: You must have been a non-resident for at least three of the previous five y...

While Portugal’s tax advantages often steal the spotlight, there’s much more that makes the country one of Europe’s most desirable retirement destinations.

Why Retirees Love Portugal:

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• 🌤 Climate: With warm summers and mild winters, Portugal offers a true Mediterranean lifestyle year-round.
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• 💶 Cost of Living: Daily life — from groceries to housing — is noticeably more affordable than in many Western European...

Many expats feared they missed the window to apply for Portugal’s Non-Habitual Resident (NHR) regime after its phase-out. However, the 2024 Budget Law introduced extensions for those who had already begun their move before the deadline.

If you took concrete relocation steps by December 31, 2023, you may still qualify under the old NHR regime.

Who May Still Be Eligible:

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• Visa or Residence Permit Filed in Time
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• You ...

Portugal is entering a new era of tax incentives with the introduction of the IFICI (Incentivo Fiscal à Investigação Científica e Inovação) — also known as NHR 2.0.

This program replaces the long-standing Non-Habitual Resident (NHR) regime and reflects Portugal’s pivot toward innovation, entrepreneurship, and high-value economic activity.

Key Highlights:

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• Purpose: Attract global talent in research, technology, and i...