Estate planning, wills and succession

Developed and implemented gift planning strategies using GRAT structures and sales to grantor trusts.

Represented private and corporate fiduciaries in post-death trust administration matters, including preparation of federal estate tax returns.

Represented taxpayers before the IRS in audits involving estate tax, gift tax, and exempt organization issues.

Assisted a client with her estate plan to meet her goal to ensure more than half of her estate goes to giving back to her community and charitable organizations.

Advising a US based family who invested together on a "pooled basis". Even though both parents had died recently, the offspring of the family wanted to continue to invest in both real estate and hedge funds, but in varying percentages. Our lawyers structured "tracking partnerships" which allowed the family to continue to invest together but in different asset classes and monetary commitments.

A reorganization of the estate of a US citizen with a valuable Cayman shareholding resulted in an immediate saving for his family of over £100m tax. Involving private client as well as the family teams in the US and UK.

We advised a family on the most appropriate structure to hold an estate that has been in the family for 32 generations. A complex matter, the family wanted the estate to be held by all of their children rather than one ‘heir’ but for the ‘rules’ of ownership and transfer to be clear and fair and ensure that the family asset is retained.

Negotiating and implementing a settlement agreement between heirs, based both in the UK and in Italy, for a high net worth individual in the context of a succession whereby Italian forced heirship rules applied.

Succession planning for leading hedge fund and private equity managers with assets in or connections with Italy, France, Switzerland and the US, among other jurisdictions.

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.

Assisting and advising this family based in Taiwan with extensive business interests and assets in multiple jurisdictions. Advice includes a multi-disciplinary team covering succession planning, immigration and cross-border investment.

Our client based in North Asia, and with assets over US$1b across Asia and the UK, was concerned about his succession planning, particularly in regards to the impact of this on a child of the family with a disability. We worked with him to navigate the legal issues involved across those multiple jurisdictions and to create a plan that always had the needs of the family at the forefront.

We assisted in the probate and estate administration of a member of the family behind a successful British retail business. The deceased was UK resident ‘non dom’, but with arguable common law domicile, and survived by a spouse, children and grandchildren. He held assets globally, some within a complex web of lifetime trusts, and had made wills in different jurisdictions. We managed the difficult domicile claim, co-ordinated probate applications globally and balanced the dynastic plan for the business.

Often, Living Wills are associated with people who wish to refuse treatment should they become seriously ill and lack capacity to make decisions. However in one instance we acted for a seriously disabled client who used her Living Will to request maximum treatment, preserving her life as long as possible.