UMA Swiss AG, part of the UMA Wealth Group, had the pleasure of participating in a discussion focused on the rapidly evolving Brazilian tax, succession, and international wealth planning landscape, together with Juliana Cardoso and Alejandro Gil, followed by an engaging exchange with professionals from the private wealth and fiduciary industry.

Representing UMA Swiss AG was Geralda Kral, Managing Partner of the firm. As a Swiss licensed trustee working extensively with Latin American families, UMA Wealth continues to follow closely the growing demand from Brazilian clients seeking international succession planning and cross-border wealth structuring solutions.

The session opened with Juliana Cardoso, founder of Juliana Cardoso Advogados in São Paulo, who provided a detailed overview of the recent legislative and tax developments impacting Brazilian individuals and families.

Juliana explained how Brazil has significantly expanded the taxation and reporting framework applicable to offshore structures and international assets in recent years, particularly following the introduction of Law 14.754 and subsequent tax reforms.

Topics discussed included:

  • The taxation of offshore structures and controlled foreign companies (CFCs) held by Brazilian individuals
  • The return of dividend taxation in Brazil
  • Changes to inheritance and gift taxation (ITCMD), including taxation involving foreign assets and inheritances
  • The growing relevance of fair market value concepts in succession planning
  • The evolving legal treatment of trusts under Brazilian law

A particularly interesting aspect of the discussion centered around the increasing interest Brazilian families are showing toward trusts and international succession planning structures.

While trusts remain a relatively new concept for many Brazilian families due to Brazil’s civil law tradition, there is clearly growing awareness of their potential role in long-term family governance, cross-border succession planning, asset continuity, and international estate organization.

The session then continued with Alejandro Gil, co-founder of Sophos Advisors, who provided an overview of international life insurance solutions commonly encountered in the private wealth industry, including Private Placement Life Insurance (PPLI) structures and universal life insurance .

An important conclusion from the discussion was that Brazil is currently undergoing a period of significant legal and regulatory evolution. As a result, Brazilian families and their advisors are paying much closer attention to international planning solutions and how they may interact with future developments in Brazilian law.