Mid-2026 UHNW Briefing: US Tax, UK Rules and PPLI

Four developments deserve separate review in 2026: the introduced Senate PPLI bill, enacted US tax changes, the UK's residence-based tax rules, and private wealth-migration research. They carry very different weight: one is a proposal, one is law, one is a residence regime and one is private research. This midyear briefing, updated in September, explains what each actually changes for a family and which records you will want in hand before acting. The short version: a bill is not law, a migration forecast is not a count of people who moved, and a policy's tax treatment does not automatically follow its owner across a border.

The Senate PPLI proposal: check the bill and its status

Senator Ron Wyden introduced S. 4279, the Protecting Proper Life Insurance from Abuse Act, on April 13, 2026. The official bill-status record checked September 16 lists introduction and referral to the Senate Finance Committee on that date and contains no enactment entry. Introduction on its own tells you nothing reliable about whether, or when, the bill will pass. The Senate PPLI proposal analysis examines the introduced definition, proposed tax consequences and transition terms.

Until something is enacted, existing contracts are judged under current law. A review today still needs section 7702 qualification, section 817(h) diversification testing and the ownership analysis illustrated by Revenue Ruling 2003-91. It is also worth noting, separately, how the proposal would affect your actual contract if it were enacted. Being compliant today does not guarantee that a policy would be grandfathered later.

US tax changes: calculate the effect on the actual taxpayer

The 2025 law commonly called OBBBA is Public Law 119-21, approved July 4, 2025. Under section 2010(c), the federal basic exclusion amount is USD 15 million for 2026, with inflation adjustments after 2026. The provision has no scheduled sunset under current law, but Congress can still change it, and the USD 15 million figure will move with inflation rather than stay fixed.

Net worth is a starting point, not an estate-tax calculation. The real number depends on prior taxable gifts, how assets are owned, what is includible, and the deductions and credits available. Two spouses do not automatically share an unrestricted USD 30 million allowance, and there is no general USD 40 million household figure below which you can skip the review. Using a deceased spouse's unused exclusion generally requires a valid portability election; the IRS estate-tax FAQs explain the filing framework. State estate tax needs its own calculation.

Itemized deductions and QSBS need their own dates

From tax years beginning after December 31, 2025, section 68 reduces otherwise allowable itemized deductions by 2/37 of the smaller of those deductions or the positive excess of taxable income before those deductions and this limitation over the start of the 37% bracket. Other deduction limits apply first. The 35% shorthand describes the regular federal tax benefit of a fully affected deduction against 37% income; it is not a universal deduction rate.

For qualified small business stock, section 1202 distinguishes acquisition dates, issuance dates, holding periods and other conditions. Qualifying stock acquired after July 4, 2025 can use 50%, 75% or 100% exclusions after three, four or at least five years. Selling in 2026 is not enough on its own; the stock's acquisition and issuance dates decide which regime applies. The OBBBA planning review covers the limits and compares policy economics separately.

UK rules: separate FIG eligibility from inheritance tax

HMRC confirms that the four-year Foreign Income and Gains regime replaced the remittance basis on April 6, 2025. Broadly, it applies to qualifying UK residents within their first four resident tax years after at least ten consecutive nonresident tax years. Relief requires a claim for eligible income or gains. The November 2025 Budget discusses the implemented non-dom reforms, though the rules can still be amended. The migration estimates discussed below cannot tell you how much of any movement the reforms themselves caused.

Under HMRC's 2026 FIG helpsheet, unused years cannot be carried forward. Someone whose first resident tax year was 2022/23 could have only 2025/26 remaining within the four-year period, assuming all eligibility conditions are met. Arriving recently does not start a fresh four-year window in 2026. Claims can also remove specified allowances, so compare the full return consequences before claiming.

Leaving the UK and qualifying for FIG are different questions. Under HMRC's long-term-residence guidance, the general inheritance-tax test looks for UK residence in at least ten of the twenty tax years immediately before the relevant tax year, with special and transitional rules. The departure guidance explains that exposure can continue for three to ten tax years after leaving, depending on residence history and applicable rules. Moving abroad does not, by itself, end UK inheritance-tax exposure.

Insurance needs a separate UK review. HMRC's personal portfolio bond guidance describes an annual charge where the PPB rules apply. Keeping the same policy after a move does not guarantee that tax deferral continues. Before paying premiums, making transfers or taking withdrawals, review the benefits, investment-selection rights, whether the issuer may still service you, and local treatment. The insurance-jurisdiction guide sets out those questions in order, but only a review of your own contract can confirm how it travels.

Migration estimates and competitiveness scores measure different things

Henley & Partners' June 24, 2025 release projected 142,000 millionaires relocating internationally in 2025 and the country net flows shown below. Its global migration series identifies 2025 as provisional and uses relocation lasting more than six months. Treat these as private research estimates rather than a final count, and remember that a net flow is arrivals minus departures, not the number of people who left.

Henley's June 16, 2026 report release introduced a different measure: a competitiveness framework using 12 dimensions and 38 weighted indicators. It reports scores out of 100 of 85.3 for the UAE, 79.5 for Singapore, 75.8 for New Zealand and 74.3 for the Cayman Islands. It places the UK, Germany and France among jurisdictions under pressure. These are the publisher's own assessments. They do not count migrants, and they are not tax opinions or insurer ratings. Our wealth-mobility and PPLI-portability review explains the methodological distinction.

The practical point is simple: if a move is on the table, test it against your actual assets and obligations. A ranking cannot tell you whether your family can realistically relocate, which country suits you, or whether structuring in advance will preserve wealth in your case. A policy that remains in force can still face different tax, investment or servicing rules after a change of residence.

A practical second-half review sequence

Build the review around actual decisions and dates. A pending sale, planned move, premium payment or filing deadline determines the sequence. Keep an eye on the legislation, but keep current compliance up to date in the meantime. The list below is a working method. Adapt it to your own circumstances rather than treating it as a checklist every family must complete.

1. Review existing insurance: reconcile the contract, funding, investments, control rights and available compliance records with current requirements. Keep any proposed-law scenario separate.
2. Recalculate US inputs: confirm available estate exclusion, prior transfers, QSBS acquisition and issuance records, and deduction limitations. Compare after-tax cash flows and policy costs.
3. Establish the UK timeline: document residence years, any FIG claim, the income or gains involved and possible inheritance-tax exposure after departure.
4. Test a prospective move: use a hypothetical twelve-month planning horizon to identify documents and decisions. It is a planning exercise, not a legal deadline, and some moves take longer.
5. Assign actions: record which adviser or institution must resolve each issue, the evidence required and the relevant deadline before implementing transfers.

Keep a single decision record for each action: the owner, the relevant law, the date, supporting documents, alternatives considered and unresolved issues. Obtain the appropriate legal or tax advice before implementing a change. Migration research can help you frame the questions. The tax result, the coverage you need and whether a particular policy suits you come from advice on your own facts.

PPLI.com publishes research for families and advisers evaluating private placement life insurance. To raise a question about this briefing, send a PPLI inquiry.

Updated 16 September 2026. Published by PPLI.com. The correction of 15 September clarified legislative status and removed an unsupported estate-size threshold. This review corrects the remaining UK-rule, migration-data and deduction descriptions. Read our editorial standards.