A selection of cases to highlight our considerable expertise in cross-border or international private client work:
a) Obtained statutory Will which saved substantial inheritance tax, dealing with double tax aspects, definition of timing of "death", and administration involving complex cross-border issues given location of deceased's assets.
b) Set-up of Family Investment Company to hold offshore assets with advice on inheritance, income and capital gains tax implications, gift with reservation of benefit and shadow directorship
c) Advising Swiss family office on erroneous remittance of non-UK source income to the UK and associated solutions
d) Advising on Tier 1 investor Visa immigration process for Sudanese national and relevant pre-immigration planning
e) Advising potential trustees of non-resident discretionary trust under English law on the terms of the trust to enable them to take on the trusteeship for the purpose of terminating it and appointing all assets to its principal beneficiaries, enabling them to be free of an acrimonious trust which no longer served its purpose.
f) Advising Chinese client on UK tax planning aspects post entry into UK on entrepreneur visa, involving retrospective advice on restructuring remuneration package and financial support received from relatives in China.
g) Advising Bank Julius Bear on over 80 trust accounts acquired from Morgan Stanley as to their validly constitution and trustees’ powers over the accounts.
h) Advising South African domiciled UK resident individual on termination of South African life interest settlement and externalisation of trust assets in accordance with South African Revenue Board rules including resettlement of £10 million of assets into a Jersey trust, avoiding exposure to UK tax.
i) Advising resident non-domiciled HNW on acquisition by UK SPV of a £7.5 million property.
j) Advising on Liechtenstein Disclosure Facility matter, which was acknowledged by HMRC as the most complex case of this nature they had ever seen.
k) Complex litigation relating to Liechtenstein foundations “owned” by Russians in dispute over contracts in Balkans.
l) Acquisition by Swiss holding company of shares in Dutch company, its German subsidiary and various international contracts held in other members of seller group.
m) Advised Australian company on sale of its European business operated by English company and French subsidiary, to the market leader in the USA, including sale and part license-back of brand and intellectual property.
n) Advised Australian investors (via unit trust) on 80% investment in joint venture with Big Yellow group to acquire Armadillo self storage.
o) Advised offshore sellers on £68.5m sale of commercial property held in Guernsey Property Unit Trust, by a sale of the units in the unit trust.
p) Restructuring of property ownership to move outside charge to ATED. Complex corporate restructuring in numerous steps, some involving refinancing of bank debt to create considerable tax savings.
