The wealth structuring industry is not short of tools. Trusts, foundations, holding companies, variable capital companies, insurance structures and family investment funds are all available, each with its own strengths, limitations and jurisdictional nuances. The challenge facing advisers today is not a lack of options but the opposite: an abundance of vehicles that, without a clear organising principle, risk producing a collection of disconnected solutions rather than a coherent plan.
At the Hubbis India Wealth Management Forum 2026, held in Mumbai, the second panel discussion of the day, chaired by Rohit Bhardwaj, Country Head – India, Director Private Clients, Henley & Partners, explored the evolving landscape of cross-border wealth structuring for NRIs and Global Indian families. Among the panellists, Kshitij Kulkarni, Partner at 1291 Group, an international insurance brokerage and wealth structuring firm, brought a perspective rooted in practical client work across multiple jurisdictions. Drawing on detailed examples and a frank assessment of India’s regulatory trajectory, Kulkarni made the case that effective structuring begins not with the selection of a vehicle, but with an honest conversation about what the family is actually trying to achieve.
Key Takeaways
Clients Fall into Two Distinct Camps: Those who recognise the urgency of cross-border planning and are ready to act, and those who acknowledge the need but defer action indefinitely, each requiring a fundamentally different advisory approach.
Three Objectives Should Anchor Every Structuring Conversation: Succession planning, asset protection and consolidation remain the primary goals, and keeping them in focus prevents structuring from becoming a fragmented exercise.
Insurance Can Serve as a Wealth Equaliser: Where family circumstances produce unequal outcomes across branches or generations, insurance offers a mechanism for rebalancing that other vehicles may not easily replicate.
India’s Regulatory Environment Is Improving but Remains Layered: GIFT City represents a genuinely progressive step, though overlapping regulatory bodies and procedural bottlenecks continue to create friction for practitioners and clients.
Composite and Parallel Structures Are Becoming the Norm: Families increasingly require combinations of vehicles across jurisdictions rather than a single structure, and advisers must be comfortable designing for that complexity.
Two Buckets: The Ready and the Reluctant
Kulkarni began by identifying a pattern he encounters regularly in his client work. Families facing cross-border structuring needs tend to fall into one of two categories.
The first comprises clients who have clearly decided that action is required. They recognise the complexity of their circumstances, spanning multiple jurisdictions with different legal traditions, and they understand that a single solution is unlikely to suffice. “There are cross-border issues,” Kulkarni noted. “There is not just India. They need to plan for Dubai, they need to plan for the US, they need to plan for the UK, and each one of them is a different jurisdiction in itself.”
He emphasised the practical implications of this diversity. One jurisdiction may operate under civil law, another under common law. Trusts may be well understood in one place and unrecognised in another. Foundations may be effective in certain free zones but create unexpected tax consequences when distributions reach beneficiaries in India. The families who are ready to act tend to appreciate this complexity and are prepared to engage specialist advice accordingly.
The second group is more challenging. These are clients who acknowledge that something needs to be done but continually defer the decision. “You kind of have to nudge these clients out of this safe zone or their place of comfort,” Kulkarni said. He stressed that the advisory relationship in these cases is as much about education and encouragement as it is about technical structuring, and that having the conversation at the right moment is critical.
Other panellists reinforced this observation. One participant described how families who start late often encounter avoidable delays or, worse, find themselves unable to access the structural benefits they had assumed were in place. Another urged advisers to listen carefully before prescribing solutions, noting that the objectives of the family must be understood before any vehicle is selected.
Objectives as the Organising Principle
Kulkarni was explicit about what he regards as the foundation of any structuring exercise. Regardless of the family’s circumstances, the complexity of their holdings, or the number of jurisdictions involved, the conversation should always return to three primary objectives: succession planning, asset protection and consolidation.
“As long as you can try and keep those objectives in mind,” he said, “what you may end up with is not just isolated pockets of hardware sitting randomly around the board, but actually this cohesive structure that looks at all of those and brings them all together.”
He built on an analogy offered by a fellow panellist, who had compared structuring to assembling building blocks. Kulkarni agreed that trusts, foundations, holding companies and insurance are simply components, and that the value lies in how they are assembled. But he pushed the point further, arguing that without a clear set of objectives guiding the design, the result is likely to be a collection of parts rather than a functioning whole.
He noted that composite structures are increasingly common in practice. It is not unusual, he observed, for a foundation to act as trustee of a trust, combining the governance flexibility of one vehicle with the legal recognition of another. Equally, parallel structures, such as a Singapore trust managing one pool of assets alongside a family office in Dubai managing another, allow families to match each portion of their wealth with the jurisdictional framework best suited to it.
Insurance as a Wealth Equaliser
One of Kulkarni’s most illustrative contributions was a detailed example drawn from his client work. He described a jewellery family with three sons, each of whom had been sent by their father to a different city: one to Hong Kong, one to Dubai and one remaining in India. The father’s intention was to provide each son with three things: a debt-free home, an investment corpus, and a business to run independently.
Over a decade, the outcomes diverged considerably. Property values in each city moved at different rates. Investment portfolios, though broadly similar in allocation, produced varying results. And the business contributions of each son differed according to local market conditions. The question of how to equalise across three branches of the family became unavoidable.
“How do you equalise this?” Kulkarni asked. “You need to have that flexibility to say, yes, I want to divide equally, but maybe equally does not work ten years after that.”
His firm’s solution was to use life insurance as an equaliser, creating identical cover of ten million dollars for each son. Because the sons were different ages, the cost of each policy varied, but the net effect was to produce an equivalent financial outcome for each branch of the family. Kulkarni offered this not as a universal prescription but as an illustration of how insurance can address problems that trusts or foundations alone may not easily resolve.
The example also served a broader purpose: reinforcing his argument that advisers must begin with the family’s circumstances and objectives rather than with a preferred vehicle. In this case, the solution was not a trust or a foundation but an insurance arrangement, and it emerged only because the adviser was willing to look beyond the conventional structuring toolkit.
India’s Regulatory Landscape: Progress and Friction
Kulkarni was broadly positive about the direction of regulatory reform in India, particularly in relation to GIFT City. He described the GIFT City regulator as progressive and willing to listen, and pointed to several encouraging developments. The introduction of a variable capital company framework, modelled on Singapore’s VCC legislation, is expected to allow segregated portfolios within GIFT City. The approval of the first inbound family investment fund, a UK-based vehicle investing into India, represents a meaningful milestone. And the extension of the tax benefit period under Section 80LA from ten to twenty years, introduced in the most recent budget, has improved the attractiveness of the jurisdiction for longer-term planning.
However, Kulkarni was equally candid about the friction that remains. He noted that the presence of multiple regulatory bodies, including the government, the central bank and the securities regulator, can produce conflicting positions on key issues. He cited the family investment fund framework as an example, where initial applications involving prominent names encountered difficulties before the pathway was eventually clarified.
He also flagged a practical bottleneck. If a variable capital company established in GIFT City were to require winding up, the process would likely need to pass through the National Company Law Tribunal, which is already heavily overburdened. He suggested that a dedicated court or expedited process could alleviate this pressure, and noted that this is a recommendation his firm has already communicated to the regulator.
Drawing a comparison with Singapore, Kulkarni observed that regulatory clarity is one of that jurisdiction’s defining advantages. “In Singapore, it works in can and cannot,” he said. “You can do it or you cannot do it. India is a maybe.” He acknowledged that this ambiguity may not be entirely unwelcome for lawyers, but conceded that it creates genuine difficulty for clients and advisers seeking certainty in their planning.
The Third-Generation Imperative
In his closing remarks, Kulkarni was direct about what is at stake. He referenced the widely cited observation that the vast majority of family wealth is depleted by the time it reaches the third generation, and argued that this outcome, while common, is not inevitable.
“I would not want a father to give money to a son which only passes on to the taxman after the passing of the son,” he said. “You want to create structures which pass on seamlessly from one generation to another generation to the next generation in a manner which the way you planned.”
He urged advisers in the room to encourage their clients to think about these questions early and seriously, noting that the tools and frameworks exist to prevent wealth erosion across generations, provided the planning is undertaken with sufficient care and foresight.
Structure with Purpose
Kulkarni’s contributions throughout the panel reflected a consistent philosophy: that structuring is a means to an end, not an end in itself. The vehicles are available, the jurisdictions are maturing, and the regulatory landscape, while imperfect, is moving in the right direction. What distinguishes effective planning from ineffective planning is not the sophistication of the tools deployed, but the clarity of the objectives they are designed to serve.
For advisers working with NRIs and Global Indian families whose lives and wealth span multiple jurisdictions, the message was clear. Start with the family. Start with the objectives. And build from there, using whatever combination of vehicles, jurisdictions and instruments the circumstances genuinely require, rather than defaulting to the structures that happen to be most familiar.