#Cross-Border Tax
共检索到 2 篇相关深度研报
The 10-Year Horizon: Portugal’s Golden Visa Reform, National Tax Enforcement, and the Death of Passive Residency Arbitrage
With China’s November 2026 tax enforcement benchmarks standardizing penalties up to 500% alongside automated CRS data matching, and Portugal extending naturalization to 10 years while restricting NHR 2.0 to active researchers, cross-border investors face a sharp reckoning. Residency permits no longer shield global assets from sovereign tax residence rules.
Look-Through Taxation and the $1.8 Billion Wahaha Estate Dispute: From Dynastic Warfare to Regulatory Settlement
China’s look-through individual income tax rules for offshore trusts mandate a 20% tax across the full asset lifecycle, fundamentally restructuring the strategic game theory behind the $1.8 billion Wahaha estate battle. Legitimizing the trust now triggers dual Sino-US tax liabilities and an annual 18.25% late penalty, forcing dynastic litigation toward a tax-driven settlement.