Partner | Milan
Complying with tax law can be challenging for individuals and businesses, especially for those with interests around the world.
With an unrivalled team of more than 150 personal and corporate tax lawyers, Withers is always ready to assist in domestic and international tax planning.
Our advice is knowledgeable, reliable and solution-focused. We excel in solving cross-border and multi-jurisdictional problems. Our global team of tax attorneys includes US, UK, Australian, Japanese, Singaporean, Luxembourg, PRC, Indian, New Zealand, Russian and Italian qualified lawyers and tax advisors, all with significant international capabilities. Several are qualified in more than one jurisdiction, including a team of US tax lawyers who work in our London, Geneva, Tokyo, Hong Kong and Singapore offices, to provide integrated advice to clients in their own time zone.
We work with a broad range of successful individuals, families and companies on their interests in more than 100 countries. Our private clients include entrepreneurs, artists, athletes and city professionals. Our tax solicitors advise families who have held wealth for generations, and individuals who have received an unexpected ‘windfall’. Corporate clients include many household names amongst fashion brands, financial services firms and hotel and hospitality companies.
We were quoted by Legal 500 EMEA 2021 as a department that is 'unique in being able to offer competence and efficiency in a great variety of areas. This variety of skills, possible only through the great synergy developed between the team members, allows us to offer our own clients efficient solutions from a variety of points of view, without leaving anything to chance.'
Whatever your situation, we can help with your tax planning, when necessary consulting with leading colleagues in areas such as trusts, wealth planning, immigration and employment. This full-service offering is something that accountancy firms cannot match.
We advise on the tax benefits of charitable giving and philanthropy, an area in which we have particular experience, acting for more than 50% of the leading charities in the UK alone. And we can advise when things go wrong, with a team dedicated to tax investigations and controversy.
Each situation is different, but as a firm established more than a century ago, we can draw on a wealth of previous cases when assessing new ones. Looking to the future, we also stay on top of legislative developments, advising on the implications of major election results and keeping you ahead of tax law changes in different countries.
Throughout the world many countries have committed to redefining banking secrecy laws so as to no longer protect any form of tax offense and/or adopt more stringent information sharing standards in tax law matters. This shift to greater transparency and information sharing has caused an increase in the number of individuals seeking to divulge previously unreported income and become compliant.
Across the Americas, Europe and Asia, governments have offered various streamlined measures or amnesty programs in an effort to get individuals back into the tax net. Our experienced team of tax solicitors have helped thousands of individuals and families around the world negotiate these amnesty programs and put their tax affairs in order.
Designed the structure of a bespoke Japanese logistics fund for the benefit of a North American real estate asset manager.
Advised Indorama Group, a multi-billion dollar global conglomerate and a leading manufacturer of various products across 37 jurisdictions, on developing a tax efficient structure for a treasury hub and investment of financial assets.
Advised PremjiInvest, one of the largest multi-billion dollar financial investors in India, in an outbound investment structure integrating complex regulatory and tax issues between India and Singapore.
Acted as lead tax advisor to Pacific Alliance Group in over 20 transactions with a cumulative market value in excess of US$4 billion, in various asset classes, private equity, real estate, and alternative investments, from Singapore into Australia, Hong Kong, India, Japan, Korea, and New Zealand.
Assisted an online art dealer in setting up an Italian company involved in pooling investments in art. The company would also offer NFTs. Our advice focuses on the opportunity of setting up a start-up or an innovative Small-Mid enterprise (SME) as well as on the VAT aspects of using a "margin scheme" and the eventual implications arising from the sale of NFTs.
Our team in London is advising a senior professional in relation to tax fraud, taking him through a Contractual Disclosure Facility ("CDF"). This type of voluntary disclosure that allows individuals to own up to tax fraud, in return for a promise from HMRC not to commence a criminal investigation. He was extremely concerned about the process and subsequent investigation, but our team helped to simply and speed up the process, managing communications with HMRC and allowing the client to move on with his life.
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.
Assisting clients in negotiating disclosures under the Liechtenstein Disclosure Facility (LDF) for clients with complex offshore structures - sometimes working in tandem with US qualified colleagues when the client also needed to make a voluntary disclosure in the US.
We represented a Columbian family with interests in Columbia and Brazil, which had been briefly stationed in the United States, with a delicate IRS matter. We assisted the family in negotiating a penalty abatement of upwards of US$1.6 million in potential penalties, and all of the IRS meetings and negotiations were addressed without clients needing to be physically present in the United States.
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.
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.
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.
Represented a prominent Chilean businessman to secure and sustain his assets for his US-born descendants by allowing him to avoid US estate tax and reduce his Chilean property tax payments using usufruct transactions.
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.
Advised on the restructuring of a Colombian family's offshore assets in connection with Colombian tax reform.
Advised major financial institutions in and outside of Mexico on the use of sophisticated tax compliant investment structures for their private clients to deal with ongoing developments in Mexican and international tax compliance regimes.
Assisted a major Brazilian real estate investor to immigrate to the US, start a new business, acquire US real estate and reorganize his Brazilian and offshore investments. This involved obtaining a new passport and visas, international tax and corporate structuring, real estate advice and business planning.
Advised on UK tax aspects and co-ordinated the structuring of the purchase and use of a plane and a New York apartment for a UK resident non-domiciled individual. Our team of lawyers worked with trust professionals in many time zones and with different specialisms bringing its own challenges.
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.
We represented a US$6 billion public chemical company in a US$1.25 billion term loan and its commercial paper program. Corporate and corporate tax lawyers from Greenwich, New York and New Haven worked on these matters.
A Canadian-US family living on both sides of the US-Canadian border asked us to assist with US reporting deficiencies (FBAR, FATCA, income tax returns, entity reporting, etc), where the potential IRS penalties well exceeded USD $1 million. We successfully negotiated full penalty waiver on all missed reporting forms for all impacted family members.
Lead tax advisor for one of Philippines’ largest listed MNC in its power, banking and financial services, food, land and infrastructure investments across Singapore, Philippines, Vietnam and Indonesia.
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.
Our US corporate, corporate tax and wealth planning groups worked to close this deal, which included a purchase price allocation for personal goodwill and post-closing installment payments under promissory notes, secured by underlying shares subject to a voting agreement. The deal pay-out also included employment arrangements, insurance-related payments and a potential dividend payment.
Withers advised a family office when they wished to implement a 'tracking' partnership basis. Our team pooled the family's high-value investments into a single entity structure but allowing each family member to allocate their investments to the assets that suited them best. This tax-efficient structure was tailored to the individual financial needs of each member, their tax status and goals.
We advised the partners in relation to a review of the structure of the their business, optimizing succession planning and convert to a limited liability partnership status. We undertook an extensive review of the business and its assets. This included examining the tax profiles of each partner as well as regulatory issues, inherent business risk and setting goals for the future.
At Withers we like a challenge, so it is always pleasing to be presented with complex cases such as a reverse triangular merger on which we were instructed by a client that held extensive real estate in New York City and Long Island. Our client wished to transfer stock in the merger, and requested advice on shareholder liability as well as the state and city real estate taxes.
Our New Haven office persuaded the IRS and the state of Connecticut not to criminally prosecute a client who had failed to file individual, withholding, sales and corporate tax returns for eight years as a result of the economic downturn and some personal emotional turmoil.
Withers has extensive experience and knowledge of inheritance tax issues around the world. This means that we are often called to step in when problems arise. One executor of a will came to us when he wanted to take action against his late spouse's solicitor. We were able successfully to argue that the solicitor had failed to effectively advise about US tax liabilities on the spouse's worldwide assets during the making of her UK will.
Withers' specialist tax team has a wealth of experience working with insurers. So it's not surprising leading companies turn to us for advice on a range issues surrounding insurance premium tax. This has included assessing the applicability of insurance premium tax to employers’ liability insurance in the UK. We also conducted a major review of the application of insurance premium tax across the EU.
Withers has a century of experience in advising high net worth individuals and organizations. So we were pleased to work closely with seven principals of a $1 billion-plus fund to facilitate the most tax-efficient transfer of their interests in a new fund into wealth holding vehicles.
When the founding principals of two of London's largest hedge funds turned to Withers for help devising a more integrated approach to tax structuring in the UK and US, our international knowledge and global reach made us ideally placed to help. We came up with the most efficient strategy and also advised them on effective estate planning, whether or not they stayed in the funds.
A leading global computer component manufacturer with operations around the world, including the US, Singapore and China contacted Withers when it needed to carry out a major worldwide restructuring. Our team has lawyers across many jurisdictions and was glad to advise on issues of anti-expatriation, earnings stripping and transfer pricing.
Withers was called in when the partners of a large financial services company needed to review its structure and convert to a limited liability partnership. Our team undertook a detailed review of the business and its assets. We then advised on a fresh strategy, taking into account the personal tax profiles of the partners, relevant regulatory issues and risk management. We also helped with succession planning and the company's future goals.
Withers has a strong track record in representing high-profile and high-net-worth figures in the world of sport. When leading football manager Jürgen Klopp was approached by Liverpool Football Club to become its manager, we represented him in the negotiations for his move and the extension to his contract.
Our reputation for tax advice is second to none. This was exemplified when several major investment houses and family offices turned to Withers to advise on the tax efficiency of their investment products and to seek the optimal way of mitigating liabilities in investments.
When the founders of a highly successful software company decided to sell the business to one of the world's largest equity houses, Withers was on hand to make sure the deal ran smoothly. We devised a tax-efficient exit for the founders and reduced their exposure to any future disputes, should they arise. Since the deal was completed, the founders have also come to us when they wanted to reinvest the sale proceeds into new ventures.
The founder of this highly successful online clothing retail business wanted to sell a large stake to a leading luxury goods conglomerate. As the go-to law firm for fashion entrepreneurs, Withers was brought in to ensure that the value of our client's stake was protected and negotiate a fresh incentive package. We then worked to achieve a tax-efficient strategy for the disposal of part of the founder's interest.
15 February 2023 | event
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