Creation of offshore asset protection structures
Assisted a client family with the creation of various offshore asset protection structures for different elements of their (evolving) businesses based on differing risk, sector and geographical profiles. This involved jurisdictional reviews noting the need to manage reporting requirements and protect against forced heirship rules relevant to the family.
Wealth planning structures
Assisted a UK based family whose business is in the second/third generation on creation of wealth planning structures, including family limited partnerships, primarily for the purposes of enabling the elder generation to pass on shares in the family business to the younger generation without passing on complete control of the business until such time as the younger generation had proved their credentials.
Relocation to the UK
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 maximise remittance planning techniques with respect to sources of funds generated prior to and after his arrival in the UK.
Taxation of deferred remuneration
Advised internationally mobile employee of PE fund on taxation of deferred remuneration earned by him during UK and non UK residence periods but received the remuneration having left the UK. This involved a highly technical analysis, which was confirmed by tax counsel.
Tax implications of benefits
Advised the providers of certain employment benefit trusts on the tax implications of benefit made and to be made to employees and former employees. This involved a highly technical analysis of the disguised remuneration rules and benefit in kind rules.
'Retirement Planning for High Net Worth Individuals Post Budget', IBC Conference - 2014
'Non-UK Domiciliaries Holding Property in the UK: Structuring Options' - 2014
'Understanding the Alternative Structuring Options Available: The Opportunities and Drawbacks', IBC Conference - 2014 & 2015