Last month, the UK ended its non-domiciled tax regime. This change had been announced in 2024, but its effective date was April 2025. The way this program worked was that if you lived in the UK but were "domiciled" somewhere else, you could limit the amount of taxes that you had to pay in the UK.

Only income and gains earned in the UK and foreign income and gains brought into the UK were taxed. If foreign income stayed abroad, it was not taxed. There was still an annual charge for long-term residents of the UK, but at a high level, this is how the tax regime worked.

The advantage for a rich people is that they could decide to reside in the UK because, hey, London is pretty cool, but at the same time they could nominate a lower-tax country as their domicile. For non-rich people, this became a controversial program, and so it was swapped for tax regime based on residency.

The reason I mention this is because it seems to be having a direct impact on Milan's real estate market. Since 2017, Italy has had a flat tax regime that allows new residents to pay a fixed annual tax rate of €200,000, regardless of how much money they earn abroad.

This has proven to be attractive among rich people and, between 2017 to 2022, the program attracted 2,730 individuals according to the Financial Times. But then the UK made its change and so Italy decided to colloquially rebrand its program to "svuota Londra", which translates to "empty London" in Italian.

It became about taking direct advantage of what the UK had done. And it seems to be working even better. In 2024, approximately 2,200 high-net-worth individuals relocated from the UK to Italy, with Milan being the primary destination. This has created a notable uptick in the luxury property market — more transactions and higher prices.

Whether you agree with these policy decisions or not, they will have an impact on the fortunes of London and Milan going forward. In 2023 alone, it is estimated that individuals holding "non-dom" status in the UK paid almost £9 billion in taxes and contributed to the creation of some 44,000 jobs.

Part of this is now flowing south to Milan.

Note: None of this is tax advice.

Cover photo by ANASTASIIA BUCHINSKAIA on Unsplash

Over the weekend, Warren Buffett and his team hosted some 40,000 people in Omaha for Berkshire Hathaway's annual shareholder meeting. And during the event the 94-year-old announced that he would be retiring at the end of the year. This is after 55 years as CEO, which makes him the longest-serving chief executive of an S&P 500 company.

What a run. Thanks for all the wisdom that you have shared over the years, Warren. In honor of this milestone, I decided to go back and reread his last shareholder letter (which was published back in February). His comments on the insurance industry are particularly interesting, and naturally relevant to real estate.

Over the decades, Warren has talked a lot about the benefits of owning insurance companies, namely the "money-up-front, loss-payments-later" model. It creates a "float" of cash that can be invested in the interim. But the flip side of this benefit is that it can sometimes conceal a shitty business.

As a business, if you have to pay your costs up front before you sell your products or services, then it's pretty easy to determine if you're not making any money. But in insurance, there's a long-tail of liabilities that can be far more insidious and that may not appear for many years, or even decades according to Warren.

There's also climate change bringing more uncertainty:

In general, property-casualty (“P/C”) insurance pricing strengthened during 2024, reflecting a major increase in damage from convective storms. Climate change may have been announcing its arrival. However, no “monster” event occurred during 2024. Someday, any day, a truly staggering insurance loss will occur – and there is no guarantee that there will be only one per annum.

Think back only 135 years when the world had no autos, trucks or airplanes. Now there are 300 million vehicles in the U.S. alone, a massive fleet causing huge damage daily. Property damage arising from hurricanes, tornadoes and wildfires is massive, growing and increasingly unpredictable in their patterns and eventual costs.

In a perverse way, all of this is good for the insurance business. More economic risk means higher premiums and a greater overall need for insurance products. But you have to accurately underwrite this risk:

Properly pricing P/C insurance is part art, part science and is definitely not a business for optimists. Mike Goldberg, the Berkshire executive who recruited Ajit, said it best: “We want our underwriters to daily come to work nervous, but not paralyzed.”

This reminds me. I was speaking with one of our insurance advisors a few years ago and he made a comment that he was going to be "on risk for the project." I responded by half-jokingly saying "it's funny, you see only risk, and I see an opportunity to create something special for the city." Both of us then laughed, but there's obviously some truth to these two perspectives.

I guess I chose the right profession.

Cover photo by Chris Nguyen on Unsplash

Among other things, insurance companies now use aerial photography, combined with AI, to better assess property-level risk. Here's an excerpt from Bloomberg Green:

“Weather and catastrophe losses are running ahead of the ability to manage them, and many insurers are having trouble sustaining their business because they’re not getting the right rates,” said Jay Guin, chief research officer of the extreme event solutions team at Verisk, a catastrophe modeling firm. “AI changes the equation.”

Zurich Insurance Group AG, one of the largest insurers in Europe, uses AI powered risk-modeling software to assess catastrophe risk and often tweaks it for its own purpose.

“If there’s fire hazard like vegetation, overhang or debris in your backyard that shouldn’t be there, we can tell you to lower the risk otherwise we may not be able to underwrite you,” said Ericson Chan, chief information and digital officer of the Swiss company.

What AI allows is a level of granularity that just wasn't possible when humans were the ones who had to do it. Insurers now talk about "continuous remote risk monitoring," meaning they can use AI-powered aerial imagery to constantly check on that risky debris in your backyard.

This feels like quite an improvement for the insurance industry. But when you more accurately price risk, I would imagine that it will lead to more insurers deciding to stay clear of certain risks and certain properties, as has already been the case in places like California.

Cover photo by Pim de Boer on Unsplash