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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