Sample: the Harrow-Vidal family (fictional)

The state recaptures the wealth tax that Madrid and Andalusia waived. An El País / World Inequality Lab analysis (27 Oct 2026) found it stopped relocations between regions and pushed families into structuring instead.

Where it stands

Created by Ley 38/2022 as 'temporary' and made indefinite in December 2023. Rates 1.7% (€3M–€5.35M), 2.1% (to €10.7M) and 3.5% above, on net worth after the €700K exemption. Regional wealth-tax (IP) paid is credited, so it bites hardest where IP is bonified (Madrid, Andalusia). The 60% income shield limits the bill but cannot reduce it below 20% of the ITSGF.

Key date

31 Jul 2027 — Annual filing (Modelo 718)

How it works

Annual tax on worldwide net worth of Spanish residents (Spanish assets only for non-residents) above €3M; exempt family-business shares if conditions are met; 60% shield on IRPF + IP + ITSGF.

Basis of the range

Statutory scale on the net-worth band (low end assumes the 60% income shield and family-business exemption apply; high end assumes neither).

The exemption is $15M per person ($30M per couple) and no longer expires. Above that, 40%. The planning window is open now; the political risk is a future rollback.

Where it stands

One Big Beautiful Bill Act (H.R.1, signed 4 July 2025) set the exemption at $15M per person from 2026, indexed, with no sunset. Rate 40% above the exemption.

Key date

31 Dec 2026 — Use 2026 exemption / annual gifts

How it works

40% federal estate tax on the taxable estate above the exemption; lifetime gifts use the same exemption; portability between spouses.

Basis of the range

40% on net worth above the exemption ($30M for a couple at the low end, $15M for a single person at the high end), before planning.

Leaving the U.S. tax system is itself a taxable event. U.S. citizens who relocate are taxed on worldwide income until they expatriate, and taxed on paper gains when they do.

Where it stands

IRC §877A: 'covered expatriates' (net worth ≥ $2M or average tax above the inflation-indexed threshold) are deemed to sell all assets the day before expatriation, with an indexed exclusion of roughly $900K of gain.

Key date

No fixed date

How it works

Mark-to-market of worldwide assets at capital-gains rates; deferred compensation and trusts taxed under special rules; gifts from covered expatriates to U.S. persons taxed at 40% under §2801.

Basis of the range

23.8% on unrealized gains assumed at 30%–50% of assets, less the ≈$900K exclusion, if a member expatriates.

A business sale by a UK resident costs 24% on most of the gain; the relief for founders now saves only 6 points on the first £1M.

Where it stands

CGT main rates 18%/24% since 30 October 2024. Business Asset Disposal Relief rate 14% in 2025-26 and 18% from 6 April 2026 (on the first £1M of qualifying gains).

Key date

6 Apr 2026 — BADR at 18%

How it works

24% on gains above the annual exempt amount; 18% on the first £1M of lifetime qualifying business gains.

Basis of the range

24% on gains assumed at 40%–60% of the business and listed assets sold.

Family businesses and farms are no longer passed on free of inheritance tax above £1M.

Where it stands

From 6 April 2026, 100% relief applies only to the first £1M of combined business and agricultural property; above that, 50% relief, i.e. an effective 20% inheritance tax. AIM shares get 50% relief with no £1M allowance.

Key date

6 Apr 2026 — Cap in force

How it works

Combined £1M allowance per person, then 50% relief; instalment payment over 10 years interest-free for qualifying assets.

Basis of the range

20% effective IHT on business value above £1M per owner (one owner assumed).

The pension, previously the most IHT-efficient asset, will be taxed at 40% on death and then at income-tax rates on withdrawal by heirs.

Where it stands

Announced in the October 2024 Budget and confirmed after consultation: unused pension funds and death benefits form part of the estate for IHT from 6 April 2027.

Key date

6 Apr 2027 — Pensions enter IHT

How it works

Unused defined-contribution pension funds and most death benefits included in the estate; personal representatives liable; combined with income tax on the beneficiary the effective rate can exceed 60%.

Basis of the range

40% of the retirement/pension bucket, before any drawdown or gifting strategy.

A business sale while resident in California costs 13.3% on top of the federal 23.8%. Residency audits on departures are routine.

Where it stands

Top rate 13.3% (12.3% + 1% mental health tax); the 1.1% SDI contribution has had no wage ceiling since 2024, taking the top marginal rate on wages to 14.4%. Capital gains are taxed as ordinary income.

Key date

No fixed date

How it works

Ordinary-income treatment of capital gains at 13.3%; FTB residency audits for taxpayers who leave around a liquidity event.

Basis of the range

13.3% on gains assumed at 40%–60% of business and listed assets sold in the event.

Residence-based taxation replaced domicile. Families who arrived under the old rules now have a dated exit from the exemption and a decision to make before it closes.

Where it stands

Since 6 April 2025 the remittance basis is gone. New arrivals (non-resident for the previous 10 years) get 4 tax years of exemption on foreign income and gains (FIG); after that, worldwide income is taxed at up to 45% and gains at 24%.

Key date

5 Apr 2029 — FIG window closes for April-2025 arrivals

How it works

Foreign income and gains exempt for 4 years from arrival (with no requirement to keep them offshore); thereafter taxed in full. Protected-trust status for settlor-interested trusts was removed.

Basis of the range

45% on foreign income assumed at 2%–4% of non-UK assets, once the 4-year FIG window has closed.

Not in the Budget, but the pressure did not go away and the next fiscal event will reopen it.

Where it stands

Pushed by unions, backbench Labour MPs and campaign groups through 2025–26; Chancellor Healey's 28 October 2026 Budget did not adopt it. Remains the headline demand for the next fiscal event.

Key date

31 Mar 2027 — Spring fiscal event (expected)

How it works

2% annual charge on net wealth above £10M (campaign model), with valuation rules for private companies and property.

Basis of the range

2% on net worth above £10M (campaign model).

A recurring annual tax on net worth above $50M is back on the agenda in Washington. Passage is unlikely in 2027, but the proposals shape the 2028 campaign and the state-level copycats.

Where it stands

Democrats won control of Congress on 3 Nov 2026 and are reviving wealth-tax proposals. Reference model: Ultra-Millionaire Tax Act (2% on net worth $50M–$1B, 3% above $1B). No bill scheduled yet; a direct tax faces the constitutional apportionment problem and a presidential veto.

Key date

3 Jan 2027 — New Congress convenes

How it works

Annual 2% on household net worth between $50M and $1B, 3% above $1B, with anti-avoidance rules on trusts and expatriation (40% exit tax in the Warren bill).

Basis of the range

2% on net worth above $50M plus 1% above $1B, applied to the net-worth band you selected.

The legislative route remains open even after the ballot defeat, and the bills include a tail that follows residents who leave.

Where it stands

AB 259 / ACA 3 (2023) proposed 1.5% on net worth above $1B and 1% above $50M, with a 4-year 'exit' tail on former residents. Died in committee; sponsors have said they will refile after the Prop 40 vote.

Key date

19 Feb 2027 — Bill introduction deadline (2027 session)

How it works

Annual tax of 1% on worldwide net worth above $50M and 1.5% above $1B; phased application to residents who move out of state.

Basis of the range

1% above $50M plus 0.5% above $1B on the selected net-worth band.

Heirs would inherit the original cost basis instead of the market value, so unrealized gains would be taxed at death or on sale.

Where it stands

Named by Democratic tax writers as the legally safest alternative to a wealth tax: carryover basis, a cap on step-up above a wealth level, or taxing appreciated assets pledged as loan collateral. Included in every Democratic Treasury budget since 2021; never passed.

Key date

No fixed date

How it works

Capital gains tax (23.8%) on the appreciation of assets transferred at death above an exemption (previous proposals: $1M–$5M per person).

Basis of the range

23.8% on unrealized gains assumed at 40%–60% of appreciating assets, payable at death or on sale by heirs.

A rollback would multiply the taxable estate for most families above $10M and close the trust techniques used today.

Where it stands

For the 99.5 Percent Act model (Sanders): $3.5M exemption, rates 45%–65%, limits on GRATs, dynasty trusts and valuation discounts. Reintroduced in several Congresses; revived in the 2027 Democratic agenda discussions.

Key date

No fixed date

How it works

Exemption cut to $3.5M per person; 45% rate from $3.5M rising to 65% above $1B; GRAT minimum term 10 years; generation-skipping trusts limited to 50 years.

Basis of the range

Additional estate tax versus current law: 45% above a $7M couple exemption, minus today's 40% above $30M.

The single most likely revenue measure of the new Congress for wealthy families: it is narrow, polls well and its sponsors run the tax committees.

Where it stands

Introduced July 2026 by Rep. Neal and Sen. Wyden: holders of more than $10M across retirement accounts would withdraw half of the excess every year, taxed as ordinary income. Over 32,000 Americans are affected. Sponsors will chair both tax committees in 2027.

Key date

3 Jan 2027 — Sponsors take committee chairs

How it works

Mandatory annual withdrawal of 50% of the balance above $10M (combined IRAs, Roth IRAs and defined-contribution plans), taxed as ordinary income (37% federal plus state).

Basis of the range

First-year federal tax at 37% on a forced withdrawal of half the balance above $10M; state tax not included.

A non-EU resident buying a Spanish home would pay tax equal to the purchase price. Unlikely to pass as drafted, but it is live.

Where it stands

Announced by the Prime Minister in January 2025; a bill was registered in Congress in 2025 and has not been enacted. Remains in the government's housing agenda.

Key date

No fixed date

How it works

Additional tax of up to 100% of the value of residential property acquired by non-EU, non-resident buyers.

Basis of the range

100% of an illustrative €1.5M–€3M purchase price.

'Buy, borrow, die' would be closed by taxing the gain on assets used as collateral for personal loans.

Where it stands

Floated by Democratic tax writers after the midterms as a narrower, constitutionally safer version of taxing unrealized gains: borrowing against appreciated stock would be treated as a realization event.

Key date

No fixed date

How it works

Deemed sale of the pledged asset up to the loan amount, taxed at capital-gains rates; basis stepped up accordingly.

Basis of the range

23.8% on gains realized by pledging an assumed 10% of the portfolio per year (gain share 50%–100%).

High earners in high-tax states keep an effective $10K cap because of the income phase-down, so state and local taxes remain largely non-deductible.

Where it stands

H.R.1 (2025) raised the cap to $40,000 for 2025–2029, phasing down to $10,000 for income above $500,000, and reverting to $10,000 in 2030.

Key date

1 Jan 2030 — Cap reverts to $10,000

How it works

Itemized deduction for state and local taxes limited to $40K (2025), indexed 1%/yr, reduced by 30% of MAGI above $500K down to a $10K floor.

Basis of the range

Federal value of non-deductible state tax (≈10% of an assumed 4% income yield on net worth) at a 37% rate.

Owners of profitable S-corps and partnerships would pay 3.8% more on business income that is currently outside the Medicare tax.

Where it stands

In every Democratic revenue package since 2021 (Build Back Better, Treasury Green Books): apply the 3.8% net investment income tax to active pass-through income above $400K. Scored at over $250B; a leading candidate for a 2027 reconciliation bill.

Key date

No fixed date

How it works

3.8% NIIT (or SECA) applied to pass-through trade or business income of high-income owners, closing the 'active' exception.

Basis of the range

3.8% on business income assumed at 8% of the value of the operating business.

The wealthy tax gap is estimated at £3.6bn. HMRC is hiring family-office and offshore specialists and will use AI to pick targets. Families whose structures are not documented will be the ones mapped first.

Where it stands

HMRC published a plan to move from income/asset thresholds to a data-driven risk model for its 1.3M 'wealthy' taxpayers (income over £200K or assets over £2M): linking third-party and public data to map individuals, trusts, companies and offshore structures; more Customer Compliance Managers; expansion of the High Risk Wealth Programme; mandatory registration of tax advisers.

Key date

6 Apr 2027 — Tax-adviser registration regime starts (announced)

How it works

Risk segmentation using linked datasets; AI-flagged enquiries; specialist cross-tax and offshore teams; adviser standards enforced.

Basis of the range

Professional fees for a managed HMRC enquiry into a complex international family (£15K–£120K), excluding any tax found due.

Non-U.S. holding structures that own U.S. assets through a registered foreign entity remain inside the reporting net.

Where it stands

FinCEN's March 2025 interim final rule exempted U.S.-formed companies from Corporate Transparency Act reporting; companies formed abroad and registered to do business in the U.S. must still report beneficial owners.

Key date

No fixed date

How it works

Beneficial ownership information report to FinCEN for foreign reporting companies; civil penalties accrue daily and willful failures carry criminal exposure.

Basis of the range

Professional fees for identifying reportable entities and filing; penalties are additional.

Buying property no longer buys residence in Spain. Non-EU families need a different visa route and the tax planning that goes with it.

Where it stands

Ley Orgánica 1/2025 removed residence-by-investment (the €500K property route). Existing permits continue; new applicants must use the non-lucrative, digital-nomad or entrepreneur routes.

Key date

No fixed date

How it works

Investor residence permits no longer issued; renewals of existing permits honoured.

A one-off window to bring old offshore funds into the UK at 12% instead of up to 45%.

Where it stands

Former remittance-basis users can designate pre-April-2025 foreign income and gains and pay 12% in 2025-26 and 2026-27, then 15% in 2027-28. The facility closes on 5 April 2028.

Key date

5 Apr 2027 — Rate rises from 12% to 15%

How it works

Designation of unremitted foreign income/gains in the tax return; flat charge; funds can then be remitted free of further tax.

Basis of the range

33-point saving on designated funds assumed at 5%–15% of non-UK assets, if designated before 6 April 2027.

For a family member moving to Spain with a qualifying role, the regime removes worldwide wealth tax exposure for six years.

Where it stands

Special regime for inbound workers, directors and entrepreneurs (expanded by Ley 28/2022): 24% on Spanish employment income up to €600K (47% above) for 6 years; foreign income and gains outside the Spanish net; wealth tax and ITSGF only on Spanish-situs assets. Requires 5 years of prior non-residence and a qualifying activity.

Key date

No fixed date

How it works

Election within 6 months of registration with Social Security; taxed as a non-resident on Spanish-source income; IP/ITSGF limited to Spanish assets.

Basis of the range

Wealth tax avoided on non-Spanish assets (statutory scale) plus the 23-point income saving on up to €600K of Spanish salary.

A fixed annual cost instead of a percentage: the richer the family, the cheaper it gets. Milan has become the default alternative to London for former non-doms.

Where it stands

Substitute tax of €200,000 a year (raised from €100,000 in August 2024) plus €25,000 per family member, for up to 15 years, covering all foreign-source income and gains, with no Italian wealth taxes on foreign assets (IVIE/IVAFE) and no inheritance tax on foreign assets. The 2026 Budget debated a further increase — confirm the amount in force at the date of the move.

Key date

No fixed date

How it works

Election in the first Italian tax return; 9 of the previous 10 years non-resident; ruling available in advance; Italian-source income taxed normally.

Basis of the range

Income tax at an assumed 43% home rate on foreign income (4% of net worth), minus the €200K fixed charge.

If the family holds qualified small business stock, up to $15M of gain per shareholder can be excluded from federal tax on a sale.

Where it stands

H.R.1 (2025) raised the §1202 exclusion to $15M (or 10× basis), added tiered holding periods (50% at 3 years, 75% at 4, 100% at 5) and lifted the issuer asset cap to $75M for stock issued after 4 July 2025.

Key date

No fixed date

How it works

Exclusion of gain on C-corporation stock acquired at original issuance when the issuer had under $75M in gross assets; stacking across family members and trusts multiplies the cap.

Basis of the range

23.8% federal tax avoided on up to $15M of gain per qualifying shareholder (one holder assumed).