On the afternoon of June 24, 2026, Shi Zhiqun, partner at M&T Lawyers, was invited to speak at a private banking seminar in Hangzhou on "Wealth Management and Succession for Entrepreneurs in the Era of Tax Transparency."

Shi focused on cross-border tax hotspots and case studies, addressing compliance issues in cross-border asset allocation for HNWIs and in-depth risk response strategies under the new CRS 2.0 framework. He provided professional guidance on tax compliance, risk control, wealth preservation,and succession by dissecting cross-border compliance essentials, risk strategies, and wealth protection structures.

He analyzed the core changes and upgrades to cross-border information exchange rules, noting that tax supervision—driven by big data and AI-powered digital monitoring—has become the new norm. Automated risk alerts are now routine, and tax audits have intensified in both scope and precision, reflecting a tangible tightening of the regulatory environment.

Shi further broke down the penetrating impact of CRS 2.0 on HNWIs,detailing how tax authorities "discover" undisclosed offshore income and assets through data exchange, clarifying key determination criteria,identifying high-risk asset allocation groups, and outlining legal red lines—including administrative penalties, criminal liability, and credit risks for unreported foreign income.

Using recent cases, he reviewed enforcement pathways and outcomes in retroactive overseas income investigations and significant tax recoveries.

He also examined mechanisms for resolving cross-border tax residency conflicts, the application of tie-breaker rules, and compliance risks associated with undistributed profits held in BVI/Cayman offshore entities.

On risk response, Shi proposed a CRS 2.0 compliance framework that shifts from passive audit defense to proactive tax health management, embracing routine compliance thinking. He outlined a full execution cycle—self-review, risk assessment, corrective action, and structural optimization—along with legal remedies and professional appeal procedures for tax disputes.

He concluded with a four-step response strategy: comprehensive review and self-assessment, identity and planning clarification, proactive reporting and communication, and ongoing monitoring and refinement.

The session was well-received, combining policy insights with practical application. M&T will continue to monitor regulatory trends and client needs, delivering professional, pragmatic tax legal services to support the sustainable growth of enterprises and HNWIs.