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Blog & Insights


Panama Enacts New Economic Substance Rules:
What Offshore Companies, Foundations and International Structures Need to Know. On May 28, 2026, Panama enacted Law No. 526, introducing new economic substance requirements for certain entities earning foreign-source passive income. The legislation represents a significant development in Panama’s international tax framework and reflects a broader global trend toward requiring offshore structures to demonstrate genuine economic activity within their jurisdiction of incorporati
Jun 86 min read


The Bahamas Usufruct Interest Bill: Expanding the Architecture of Cross-Border Wealth Planning
Introduction The Commonwealth of The Bahamas has long distinguished itself as a leading international financial centre, consistently demonstrating a willingness to innovate within its legislative and regulatory framework. The proposed Usufruct Interest Bill, 2026 (the “Bill”), currently under consideration by the Bahamian legislature, reflects this commitment to maintaining competitiveness in the global private wealth sector. Although the Bill has not yet been enacted, its po
Apr 44 min read


Brazil’s Complementary Law No. 227/2026 and Its Impact on Inheritance and Gift Taxation (ITCMD).
Complementary Law No. 227/2026, enacted as part of the regulatory framework implementing Constitutional Amendment No. 132/2023, establishes nationwide tax guidelines and introduces structural adjustments to Brazil’s constitutional tax system. Among its provisions, the law sets forth general rules applicable to the Tax on Inheritance and Gifts (Imposto sobre Transmissão Causa Mortis e Doação – ITCMD), a state-level tax with growing relevance for individuals holding assets or c
Jan 262 min read
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