Tax

Complying with tax laws 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 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. We 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.

Seeing the bigger picture

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.

A wealth of experience

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. ‘We’ve got a huge amount of experience in dealing with tricky situations,’ says partner Claire Harris. ‘To the extent that there’s any type of complexity, we’ll have seen something like it before.’

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 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 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.

Global understanding

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. We have helped thousands of individuals and families around the world negotiate these amnesty programs and put their tax affairs in order.

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Recognition

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

Ranked in top tier for personal tax, trust and probate

Ranked for tax: contentious trust

Wealth Management - Law Firm of the Year 2017

Leading firm - Tier 2 for tax and trust in Singapore

UK top 25 private client law firm 2017

2014 Acquisition International M&A Tax Team of the Year - USA

Ranked nationally in the US for trusts and estates and tax law by Best Lawyers 2017

Leading firm for private wealth

Ranked in Chambers HNW 2016 for Private Wealth Law in Switzerland

Winner of best tax/accountancy team in Hong Kong

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We have used Withers for specialist tax, trust and regulatory advice in Hong Kong, Singapore, Geneva and the Bahamas. The firm’s international team provides sophisticated solutions that suits the complex needs of our clients.

Antonio Ribeiro, Managing Director - Rhone Trustees (Singapore) Ltd
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Withers understands the complexities of US domestic and international planning, and provides sophisticated guidance on navigating the complexities of both tax and international planning.

Jackson Hole Trust Company
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I have worked closely with Withers for years. They are a very effective law firm for international tax matters and I am confident that in each case we work on together we will be guided by their experience and insight.

David Russell QC, Outer Temple Chambers, London and Dubai
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David is my attorney and a trusted advisor for many clients I work with. He helps clients identify objectives and draws from a vast knowledge of tax and T&E to address the need.  I depend on David for all aspects of my financial and family plans.

Hedge fund manager
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The advice I receive is excellent.  The team is very responsible, responsive, competent, pleasant to deal with and earned my trust.  I would recommend Withers Bergman highly.

Robert Cohn, retired Founder and CEO - Octel Communications Corporation
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Our aim is to help our clients stay at the cutting edge of the market, and we expect our legal partners to have a sophisticated global view that provides our clients with accurate and cost-efficient solutions to their legal problems. We have worked with Withers for many years.

ab
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We enjoy working with a dynamic US/UK legal team in London and now collaborate across a wide range of practices within the firm. Acting together, we are able to offer advice on virtually every aspect of a client’s tax and financial planning.

Buzzacott
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We have worked very closely with Jim Brockway and the Withers’ insurance team in developing some of the most innovative insurance strategies in the world.
Crown Global Insurance
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Withers is the law firm we look to for legal issues for our US/UK clients; often with a complex tax background.  The firm’s depth of knowledge and experience is excellent, on all trust and tax related legal issues, including tax controversy.

Julian Nelberg, Director - PwC
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Withers has advised us on issues relating to all of our international offices.  The firm has a well-established pedigree as trust and tax lawyers, and we value their input on commercial and litigation matters as well.  The responsiveness and the quality of their professionals across the world is impressive.

Nerine Trust Company Ltd

Meet the team

How the tax team can help

Track record

Jürgen Klopp

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.

A computer component manufacturer

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.

Aboitiz Equity Ventures

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.

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.

Software entrepreneurs

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 an online clothing business

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.

Large investors

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.

Senior professional involved in tax fraud

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.

Hedge fund founders

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.

Negotiating voluntary disclosures

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.

A large private equity fund

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.

An estate executor

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.

International insurance companies

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.

A leading financial services company

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.

A family partnership

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.

A New York financial services company

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.

A financial services company

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.

A US citizen who had not filed tax returns

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.

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.

A tobacco company CEO

Our senior executive team negotiated a favorable severance package for the outgoing CFO of this major global brand, ensuring that the payout was made tax efficiently and that other terms were met.

Managing Canadian-US reporting obligations

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.

California–based recreational vehicle company

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.

A public chemical company

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.

Structuring international assets

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.

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.

Major Brazilian real estate investor

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.

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.

Chilean businessman

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.

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.

Colombian family offshore assets

Advised on the restructuring of a Colombian family's offshore assets in connection with Colombian tax reform.

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.

Financial institutions in Mexico

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.

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.

Columbian family IRS case

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.

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