Cross-border planning

A majority of our clients now hold interests in more than one country, and we have a wealth of experience in cross-border estate planning.

Our team includes lawyers who have previously worked for tax authorities, which puts us in a strong position to negotiate with them where necessary. In a recent dispute over UK inheritance tax, we persuaded HMRC to accept that the deceased was not living in the UK when he died and was actually domiciled in Hong Kong. In a case where neither a British client nor her initial advisers had realized that her husband’s US property would incur estate tax there, we negotiated with the IRS to prevent her incurring a late payment fine.

‘These types of problems are not things families often think about’, comments Chris King, special counsel in London. ‘In the past people have tended to consider each jurisdiction separately but unfortunately that can cause unintended consequences. One strength of this firm is that we can draw on sophisticated advice from lawyers qualified in different jurisdictions working in offices around the world. This means we can deliver cohesive advice where our clients need it in local time.’

Jeremy Crickard, a partner in our California office adds ‘we have particular strengths in cases with a US/UK dimensions such as couples with one partner from each country, and in Continental European jurisdictions which we often handle from our Milan, Geneva and London offices. If you have assets in more than one country and family who are globally dispersed, our lawyers will create the best plan for you taking into consideration cross border regimes to effectively plan for your future.’

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14 July 2017 - Article

Foreign affairs: A primer on international tax and estate planning (Part 1)

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Leading firm - Private wealth law in the USA

Leading firm - Private wealth law in the USA

Ranked in Band 1 for private client for the last 16 years

UK top 25 private client law firm 2017

Leading firm for private wealth

Ranked in top tier for personal tax, trust and probate

Wealth Management - Law Firm of the Year 2017

Leading firm - Tier 1 for private wealth in Singapore

Leading firm - Tier 2 for tax and trust in Singapore

Leading firm - Band 1 for private client in Hong Kong

Winner of best legal team in Hong Kong

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Meet the team

Track record

UK child entitled to cross-border estate

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.

Structuring trusts for wealthy Argentine family

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.

Cross border wills

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.

Cross border trust and estate planning

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.

Billionaire Mexican family

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.

Tax planning when relocating

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.

US satellite family office

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

High-net-worth individual relocating to Italy

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.

IPO trust structuring

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.

Brazilian family

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.

Clients in Chile, Mexico and Venezuela

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.

Brazilian family offshore structuring

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.

Pre-immigration planning for Brazil-USA move

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

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.

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