Evergreen's founder won his will in 2024. Ten years after his death, not one share has been divided

Start with the structural difference, because for a Taiwanese family it is the largest one. Taiwan gives statutory heirs a reserved portion under Civil Code article 1223: even a valid will that leaves everything to one son cannot displace the fraction the law guarantees the others, and they can sue to reduce the gift until it is restored. Singapore has no forced heirship for non-Muslims. A Singapore will that leaves the group to one child is not vulnerable to a claw-back claim by the siblings; the Inheritance (Family Provision) Act 1966 allows a limited claim, but it is confined to maintenance for a narrow class of dependants and is nothing like a guaranteed share of the estate. In Singapore, the fight that has occupied this family since 2024 — the one that starts after the will is upheld — would largely not exist. That is the single biggest reason Taiwanese founders look at Singapore, and it is worth stating plainly rather than in a brochure.

Then the instrument problem, which is universal. The foundation is not suing on a deed of gift. It is suing on a book, and on an interview given on 7 February 2012. Whether that amounts to a gift upon death now turns on whether the foundation can prove it accepted a definite offer — a contract, not a wish — and the honest answer is that public generosity is very hard to convert into an enforceable promise years later. Singapore would not make that easier; it would make it unnecessary. A founder who wants his residue to go to his foundation settles a charitable purpose trust in his lifetime, funds it while he can sign, and the money is the foundation's on the day the deed is executed. It is not a claim to be litigated against his children; it is an asset already outside the estate. Saying it in a memoir is the most expensive way to make a gift, because it produces the intention without the transfer, and the intention then has to be proved in court against the people who inherited instead.

Now the executors and the clock, which is where a Singapore structure earns its keep in practice. Four executors hold NT$16.1 billion in a joint account they cannot distribute while the reserved-portion claims, the division suit, the removal application and now the foundation's claim are all live — and Taiwan's estate tax does not wait for any of them. The return is due within six months of death and payment within two months of assessment, and payment in kind is limited to taxed property inside Taiwan, so overseas holding-company shares cannot settle the bill. An asset settled into a Singapore trust during the founder's lifetime is not in that queue at all: it is not in the estate, there is nothing to divide, no grant is needed, and the trustee can distribute or lend on the day a deadline falls. Singapore supports the architecture directly — a trust term of up to 100 years, no public trust register, and section 90 of the Trustees Act 1967 shielding a Singapore-law trust with Singapore-resident trustees from foreign forced-heirship claims where the settlor was neither a Singapore citizen nor Singapore-domiciled when the trust was created, which a Taiwanese founder ordinarily satisfies.

Three honest limits, because this is a counterfactual and not a sales page. First, section 90 binds a Singapore court and not a Taipei one: a reserved-portion claim over Taiwan-situs assets is still decided in Taipei under article 1223, and Chang Kuo-wei's argument that the overseas estate should escape the reserved portion is precisely the point Taiwanese courts have not settled. Second, Singapore changes nothing about the tax: Taiwan taxes the worldwide estate of a founder habitually resident there, and because Singapore charges no estate duty on deaths on or after 15 February 2008, there is no foreign tax to credit — the Taiwanese bill is the whole bill. Third, and most important, none of this is available at the end. A settlement made in 2014, at the same moment as the sealed will, would have been attacked on the same grounds by the same son. The window is the decade when nobody would think to ask — which is to say, the years a founder spends assuming there is still time.