Announcement No. 21 is the live reminder: on 24 July 2026 China published rules taxing offshore trusts at a flat 20% across contribution, existence and termination, attributing undistributed income to the resident individual annually, and gave existing structures 90 days to file. A structure built in 2021 had its economics rewritten in a quarter.

Canada already does a version of this: section 94 can deem a non-resident trust to be resident where a Canadian has contributed to it, pulling its income into the Canadian net. An offshore structure whose only value is the current treatment of offshore structures is not a structure. It is a bet on a rule.