OBBBA and the Global Wealth Shift: What Private Client Advisors Must Know Now

Date: 19 Nov 2025

Karen Jones

What Is OBBBA and Why It Matter for Global Wealth. The One Big Beautiful Bill Act is more than political theatre. It is a binding tax blueprint that is reshaping global wealth flows, estate planning and cross border structuring for private clients and family offices. From China to Switzerland and the UK, advisers report capital moving out of the United States, renewed interest in offshore structures, and relief at a permanent 15 million dollar estate tax exemption from 2026, alongside targeted changes such as a softened remittance tax and revised downward attribution rules. For wealth managers, OBBBA is both an opportunity to lock in planning certainty and a warning sign that investors are quietly rebalancing away from US risk.

The enactment of the “One Big Beautiful Bill Act” (OBBBA) marks a critical inflection point for global wealth flows and cross-border financial planning. While the bill may read like political theatre, its provisions, ranging from altered estate tax thresholds to targeted excise levies, carry real-world implications for private clients, family offices, and the advisors who serve them – some positive and some negative. Wealth managers from London to Zurich to Hong Kong are already responding, and for good reason: OBBBA may be the clearest signal yet that the tectonics of wealth jurisdiction, tax policy, and investor sentiment are shifting.

To understand the practical implications of OBBBA, it’s essential to examine its impact across key jurisdictions, each responding to the bill through the lens of their local legal, fiscal, and strategic priorities.

View from China: Caution and Capital Reallocation

Estimated reading time: 11 minutes

Clifford Ng is Co-Managing partner of Zhong Lun’s Hong Kong office, Zhong Lun law firm. Having worked with some of Asia’s leading businesses and families for over 30 years, Clifford provides strategic advice on cross-border transactions and investment, tax, regulatory, estate planning, asset preservation, and governance. Zhong Lun has nearly 400 equity partners and over 2,200 professionals working across 18 offices, including London. The firm has grown to become one of the largest in China.

Ng says, “Unlike the whiplash tariff announcements, the OBBBA is actually law. It is the economic blueprint for the next four years at least and will have long-lasting impact on the US which, in turn, will have wide-ranging implications on the rest of the world. If the law does what some prognosticators say, the tax breaks and program cuts will exacerbate the many divisions in the US. If there will be higher deficits, will foreign investors continue to fund these and at what cost (especially if they will have fewer USD from lower trade surpluses if tariffs do their jobs). If – and there is a lot of “if’s” – the “blame the world” narrative prevails in the US, the rest of the world needs to pivot very quickly to find a new world order. We are already seeing investors pull back from the US. Hong Kong has been a beneficiary of this with a strong rebound in the local capital market.”

This means that OBBBA’s binding legal nature, unlike previous trade announcements, makes it a more serious influence on long-term investor behaviour.

Switzerland: Wealth Movement & Offshore Interest

Daniel Leu, Partner and Co-Head of the Private Clients Team at Baer & Karrer a leading Swiss law firm with over 200 lawyers says. “As a Swiss lawyer, I may not be the right person to provide deep analysis on OBBBA, however, my understanding is that it does not substantially affect succession planning for our clients. That being said, we see an increase in relocations from the US to Switzerland as well as US citizens shifting part of their assets from the US to Swiss banks.”

Demonstrating that OBBBA is triggering more interest in jurisdictional diversification.

UK Clients Face Tax Policy Shifts and Estate Planning Updates

Josh Matthews, Managing Partner & Co-Founder of Maseco Private Wealth, based in London, who offer wealth management for US Residents with a global investment perspective agrees and confirms, “‘Due to the uncertainty in the direction of the current administration’s policies, some wealthy Americans are contacting us about moving a portion of their portfolio outside of the US to custody in non-US jurisdictions such as Switzerland.’ Asking about the size of the capital ‘on the move’ he says, “individually only in the millions but in aggregate in the tens of millions.”

Emily Aristidou, Senior Manager in the Expatriate Tax Services team, Buzzacott, a top UK accountancy firm based in London, says: “Trump’s One Big Beautiful Bill Act has been greatly discussed both before and since it was signed into law on 4th July. Its name certainly lends itself to a headline, something I imagine was no mistake by the ever-theatrical president. And headline worthy the Act is too; Trump delivered on many campaign promises with this bill and several of the statutes will be welcome news to high-net-worth Americans in the UK.”

Key Tax Wins and Remittance Tax Changes in OBBBA

Aristidou continues, “From the lower 37% marginal tax rate which is now here to stay, to the again inflation indexed estate allowance, there was a lot of good news in the bill for our clients. Of more concern was the newly announced Remittance Transfer Excise Tax. Initially proposed as a 5% tax on all transfers out of the US, this was considerably watered down as the Act passed through Congress and was signed into law as a 1% excise tax on transfers out of the US made via cash or similar physical instruments. The carve outs for transfers made via US credit or debit cards and transfers originating from accounts held in or by most commercial financial institutions, means I do not expect this to be the problem it was initially feared to be.”

This means high earners can plan with confidence knowing their top tax rate won’t rise, and the estate tax allowance will keep pace with inflation, supporting long-term inheritance planning. It also means that, for most clients using standard banking channels, the new remittance tax will have little to no practical impact.

“One tax change promised but not brought into the bill and certainly of interest to Americans in the UK,” adds Aristidou, “is the end of citizenship-based taxation in favour of a residence-based tax system. We will wait to see if Trump has another Big Beautiful Bill up his sleeve before his term is up.” This means that, for now, Americans living abroad must still file and pay U.S. taxes regardless of where they reside, a change many had hoped would be dropped.

Impact of OBBBA on Charitable Entities and Family Office Philanthropy Henry Mander, Partner, Partner – Global Head of Trusts & Private Wealth, Harneys law firm, based in London adds his view. “We have been hearing all year about how much the philanthropy industry in the USA has been affected by changes made by the new US government, such as the cuts to US Aid. In respect of OBBBA specifically, we understand that there are adverse changes to the section 501(c)3 status enjoyed by many charitable entities and this is likely to cause some off them to move away from the USA, in particular for their non-US grant giving arms. This is something where an offshore jurisdiction in the Americas, such as Cayman, could be able to make real inroads into the international philanthropic space, especially for Family Offices.”

Estate and Succession Planning: Mixed Impact

Darcy M. Katris, Partner & Co-Chair, Family Office, Morrison Cohen who represents clients with family offices gives her view. “The only part of the bill that affects my clients and that they were concerned about, was that the estate tax exemption was scheduled to sunset at the end of this year. OBBBA increases the estate tax exemption to $15M in 2026 with no sunset. My clients are relieved with this result so early in the year.”

So instead of dropping back to around $7 million in 2026 as previously scheduled, the estate tax exemption will rise to $15 million per person, and stay there, giving clients far greater certainty and flexibility in long-term succession planning.

OBBBA’s Limited Impact on Estates, but Growing Offshore Concerns

Joshua Rubenstein, National head of the firm’s Trusts and Estates practice at Katten, a New York based law firm, with approximately 700 attorneys in locations across the United States and in London and Shanghai, says. “Whilst there have been dozens of articles on OBBBA, other than its ridiculous name, I think very little of it relates to estate planning, and it won’t have much impact on UHNW individuals, whose assets are well above the increased exemptions. It is mainly about other things. And it’s highly technical.”

Rubenstein adds. “In my view, OBBBA is the latest in a series of irresponsible Trump led initiatives that is not only causing the world to rethink investing in or moving to the US but also causing US citizens and residents to start moving their money into offshore trusts governed by a different legal system. There is not much one can do to protect ones US real estate assets from retaliatory behavior, such as freezing or even confiscation, but increasingly people are looking to move their US financial assets beyond the reach of Trump-appointed regulators.”

The implication are that many advisors are not only concerned about client risk but increasingly frustrated by the lack of stability in U.S. tax and regulatory policy, leading to a growing shift toward offshore planning as a defensive strategy.

Corporate Tax & Downward Attribution Rules

Simon Beck, partner and chair of the North America Wealth Management Group at law firm, Baker McKenzie’s New York office offers his insight. “While there are no material changes for estate planning purposes, there is a significant change about attribution of passive income and undistributed operating income from companies to US family members under the so-called downward attribution rules. These are complex and have caused major tax planning problems since the enactment of the TCJA in 2017. The OBBA reinstates the prior limitation on downward attribution for tax years after December 31, 2025, which will be a huge relief to US family members.”

Beck underscores a key technical reversal in the bill: the reinstatement of pre-2017 rules limiting ‘downward attribution.’ While opaque to the layperson, this is a meaningful change for families with international business interests, helping to prevent inadvertent US tax liabilities on passive income.

Financial Advisory & US Economic Outlook

Rising Deficits and Borrowing Costs: Planning for Uncertainty in Client Portfolios

Mike McGregor, Financial Adviser, Cross Border Financial Planning who specializes in providing financial advice to British expats and foreign nationals living in the UK offers his thoughts. “One key area to watch because of the OBBBA is the anticipated swelling of the US deficit and the knock-on consequences of this. Whilst this can have a significant impact on the US job market, one additional area of concern is that of increased borrowing costs, which in turn can have knock-on effects on US companies being able to invest for the future. Given that there has been a recent cooling in this area, combined with wider uncertainties around the world, this certainly has the potential for growing unease in the US economy. Whilst we cannot be certain of what is around the corner, it continues to be of significant importance for us to ensure sufficient diversification in client portfolios in terms of asset class, sector and geographical region.”

Taken together, these viewpoints underscore the complex, multi-jurisdictional impact of a bill that, despite its theatrical branding, demands some attention from the global advisory community.

Balancing Certainty and Concern: What OBBBA Means for Wealth Planning

The OBBBA marks a pivotal legislative moment, not for its theatre, but for its substance. For private clients and their advisors, the most significant development is the permanent extension of the estate tax exemption to $15 million per individual starting in 2026, replacing the scheduled reversion to pre-2017 levels. This shift removes a looming source of uncertainty and opens the door for more confident, longer-term succession planning. Equally important, other elements of the Act, such as the scaled-back remittance tax and the reversal of downward attribution rules, will ease some of the more burdensome complexities faced by international families and globally mobile capital. For many, this legislation is a welcome clarification of the rules of engagement.

Yet, for all the positives, the broader picture is more complex. Rising deficits, protectionist rhetoric, and an increasingly transactional approach to global policy are already leading some investors and families to hedge their exposure to the US. Wealth movement into neutral or stable jurisdictions like Switzerland, Hong Kong, or Cayman is not a rejection of the US per se, but a reflection of prudent diversification.

In this environment, the role of the advisor is more vital than ever, to seize the structural opportunities OBBBA presents, while preparing clients for the longer-term implications of fiscal drift and geopolitical change. The most resilient strategies will be those that acknowledge both: the certainty codified in today’s legislation, and the uncertainty still quietly gathering at the edges.

Key Takeaways

The OBBBA reshapes global wealth flows and introduces significant tax changes impacting estate planning and cross-border structuring.
Advisers observe capital moving out of the US, with increasing interest in offshore structures, particularly in Switzerland and Hong Kong.
Wealth managers highlight OBBBA as an opportunity and a warning, reflecting shifting investor sentiment and rebalancing away from US risk.
The permanent estate tax exemption of $15 million starting in 2026 provides planning certainty for high-net-worth individuals.
Despite positive elements, rising US deficits and protectionist policies drive concerns, prompting a shift towards diversification and offshore planning.

Subcribe here

Read about our Forum

Citywealth Leaders List Top 100 Trust Litigators

Read about pets in divorce

Read a Bindmans update

Read about getting recommended on the Citywealth leaders list

Read about the Summit Group purchase of R&H trust

JTC Group acquires Citi

Read a 60 second interview from Addleshaw Goddard

Evelyn Partners new head of financial planning

Citywealth Forum speakers 2026

Schellenberg Wittmer news