What is the impact of DAC6 on the popular structures used by HNWI: private holding company, trusts, Stiftung, Unit-linked life insurance contract, donation of a securities portfolio, use of offshore companies, Luxembourg dedicated fund (SICAV SIF), transfer of financial assets to a foreign bank. For each structure, what are the possible hallmarks? Who is an intermediary? What is the “first step of implementation” of the structure?