The following is my answer to a Quora
question: “Can I hide my assets in a foreign trust for the benefit of my
children?”
You could do that, and you
would not be the first. From a
Singapore-based consultant’s perspective, I have clients from neighbouring,
developing countries, with convoluted and corrupt tax regimes, who choose to
set up trusts in Singapore. They do this
to take advantage of our robust legal framework, our reputation for
incorruptibility, and the lower tax regime.
Singapore imposes no estate tax and no capital gains tax.
Indonesia’s tax rate sits
around 30 per cent across the board, a burden that includes CPF-equivalent
contributions for Indonesians with Singapore Permanent Residency. Tax has always functioned as a political tool
as much as a fiscal one. Indonesian
Chinese are more likely to face enforcement scrutiny than other Indonesians
holding comparable wealth, regardless of the stated legal criteria.
China has now joined this
dynamic at a larger scale. Announcement
No. 21, issued by China’s Ministry of Finance on 24th July 2026,
imposes a 20 per cent tax on offshore trusts at establishment, at every year of
operation, and at termination, reaching back retroactively to assets moved into
trusts since 2023. Families face a
declaration deadline of 22nd October 2026. A trust structure that once shielded a family’s
wealth from Chinese tax exposure now triggers the tax event it was built to
avoid.
“Hiding” was
Always the Wrong Word
Wealthy Indonesians have long
bought large insurance policies, assigned them to an irrevocable trust, and
layered ownership across several structures.
This remains perfectly legal.
Fund movements are easier to justify inside a major financial centre
than inside a jurisdiction where tax enforcement doubles as political
pressure. Most wealthy individuals
accept paying tax where they can see it working, funding roads, schools, and
institutions that benefit them directly.
That confidence collapses in corrupt nations, where tax revenue
frequently disappears into someone’s pocket rather than the public good.
You are not hiding assets in
this arrangement. You are assigning them
to a distinct legal entity for tax mitigation and security, a distinction that
matters more now than it did in 2019.
CRS 2.0 Changes
the Compliance Conversation
The Common Reporting Standard’s
second iteration took effect from 1st January 2026 across more than
46 jurisdictions, widening reportable assets to include crypto and e-money, and
demanding granular reporting on controlling persons and joint account
structures. Self-certification, the
loose foundation earlier structures relied on, has tightened. A trust structured in 2019 on the assumption
that CRS reporting stayed static has already fallen behind a regime that now
sees more of what it holds. Declared
figures under Announcement No. 21 must also match what foreign governments have
already reported to Beijing under CRS.
Silence is not a viable strategy under either framework.
Jumbo Life
Insurance Now Does the Job a Trust Used To
A directly held life insurance
policy, a universal life plan structured properly, is not a trust or a
trust-like arrangement. Announcement No.
21 targets trusts specifically. Premiums
paid into a policy are cash contributions, not appreciated assets crystallising
a taxable gain on entry. Cash value
growth accrues under insurance law, not trust law, and generates none of the
annual reportable trust income Beijing’s rule was built to capture.
A jumbo universal life policy,
held directly or layered with a Death Benefit Bequest Option for staged payouts
to the next generation, delivers what a trust delivered in 2019: wealth
protection, tax mitigation, and legacy security for families in volatile
jurisdictions, without triggering the exact tax mechanism now built
specifically to catch the older structure.
This remains especially necessary for wealthy individuals in politically
unstable nations, where wealth faces seizure risk, and where the instrument
protecting that legacy now needs to survive scrutiny under CRS 2.0 as well as
domestic political pressure back home.
Terence Nunis | Executive Chairman, Equinox Zenith | Author, The 1% Playbook: The Billionaire Cheat Code

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