Cross-border planning

Advising a number of clients who are domiciled in India and Pakistan on the structure of their wills to maximize the possibility of tax treaties with the UK applying on death. This can protect UK assets from charges to UK inheritance tax notwithstanding the clients being UK deemed domiciled through long term residence.

Represented a wealthy Argentine family to structure trusts for both their personal and business interests. Our planning allowed this family to minimize domestic wealth tax, ensure compliance with US tax regulations, form a voting trust for the family business and facilitate commercial lending transactions.

Assisting a wealthy Southeast Asian individual with cross border trust and estate planning of his substantial listed stakes on the KLSE and UK real estate interests.

We acted for the son of a deceased German businessman who was entitled to a share of a cross-border estate worth in excess of £35m. The case raised complex conflict of law issues over the deceased's Will and arguments from some of the heirs that the son had no entitlement. We co-ordinated simultaneous proceedings in England and Germany and the case was ultimately settled out of court.

Creating multiple trusts, and private trust company arrangements to govern them, for a billionaire Mexican family to ensure compliance, confidentiality and efficiency in the management of their non-Mexican assets.

Advised several high profile families in relation to tax planning strategies for their moves to the UK from countries including Canada, France, Poland, Russia, Spain and the US.

Set up a US satellite family office for a wealthy Peruvian family to facilitate their US investments.

We advised our client, who was formerly living in the UK, in his relocation to Italy under the new Italian resident non-domiciled regime, which he has been authorized status of. This was the first green light issued from the Italian tax authorities on the newly-introduced regime, made possible by our cross border team in Milan and London.

Advised a Russian client on relocating him and his family to the UK in the context of the UK statutory residence test, including advising on managing the tax implications of his role in the business, purchase and use of residential and investment property in the UK and elsewhere (such as appropriate property holding structures) and detailed advice on how to maximize remittance planning techniques with respect to sources of funds generated prior to and after his arrival in the UK.

Acted for the founder of a significant international company with PRC activities in relation to pre-IPO trust structuring. The matter involves a complicated scenario in which the trust needs to account for potential US beneficiaries as a well as PRC resident status in relation to the settlor. We are advising in relation to HK, BVI and US tax and trust advice, regulatory advice and coordinated PRC advice. This is a cross-border matter involving Hong Kong, PRC, BVI and the US.

Aided a Brazilian family with significant US commercial real estate holdings to restructure the ownership of this property to avoid US estate tax. Also devised arrangements for Brazilian residents to create legitimate structures that are protected from Brazilian taxation, permit efficient repatriation of capital to Brazil when needed and ensure optimal flexibility and family control to respond to changing needs and tax laws in the future.

Advised clients with cross-border interests in relation to the construction of private trust company structures, which effectively allowed for family business succession planning, cost reduction and greater control over certain trust decisions and tax minimization in the jurisdiction of domicile and internationally.

We worked alongside Brazilian counsel to advise a client on the FATCA and CRS reporting requirements applicable to their complex succession structure for his offshore assets. These included a private trust company, trusts, companies and other entities, a private investment fund and multiple investment accounts, and involved the Bahamas, the Cayman Islands, Switzerland and the US. The advice also needed to take into account the client's plans to relocate his family from Brazil to London, and possibly thereafter to New York City.

A Brazilian private equity fund executive requested advice on pre-immigration planning in connection with his relocation to the United States. We helped to coordinate the timing of his tax recognition from certain transactions to occur while he was still a Brazilian tax resident and others to be taxed after becoming a US tax resident. We also established different types of trust structures to protect assets from US estate tax, a foreign trust to defer income taxation on existing carried interests, and a traditional US estate planning trust for carried interests not yet paying out.

Preparing a Will in respect of a terminally ill individual with assets in jurisdictions including Hong Kong, Singapore and the US (value in excess of US$500m). The Will created a testamentary trust that, following the administration of the estate, allowed for assets to be decanted to a US trust. Following the testator’s death, we oversaw the administration of the estate.