Fiona has built up an in-depth understanding of the personal tax needs of her high net worth clients, and helps them mitigate their exposure to UK tax both during their lifetime and for future generations. She has a great deal of experience in working with families with complex asset-holding structures and diverse tax profiles.
She regularly advises individuals who are planning to become tax resident in the UK on personal estate planning that may need to be considered prior to arrival, as well as the scope and impact of UK taxation that will apply to them when they become resident.
Fiona also acts for a number of UK families wishing to plan for the succession of their personal and business assets. In addition to ensuring Wills and Lasting Powers of Attorney are in place, Fiona can assist with inter-generational discussions and the composition of family constitutions.
Recent experience includes:
- Advising a Middle Eastern family on the acquisition of an extremely high value UK asset. Included advising on the establishment of two Jersey discretionary trusts (a finance trust and an asset holding trust) and the UK tax implications for both the trustees and for any future UK resident beneficiaries of the trusts. Fiona continues to work closely with the family’s trusted advisers and the trustees on operational matters.
- Advising on UK property taxes for residential real estate held in corporate and/or trust structures and the options available to “de-envelope” such properties in order to minimise exposure to double taxation.
- Advising an international family on the re-organisation of a complex cross-jurisdictional trust arrangement. The structure was designed to assist with the ultimate succession of the family business in a tax efficient way. Considerations included retaining an element of control and involvement for the client’s family and trusted advisers, incorporating flexibility to provide for the needs of several generations of beneficiaries and ensuring a high level of confidentiality in the structure.
- Advising the trustees of a series of Jersey family trusts on the UK’s taxation rules relating to non-UK trusts. Working closely with the trustees to identify the source of funds so that an income distribution could be made from one of the trusts to fund a beneficiary in advance of his relocation to the UK. Close monitoring of the application of the UK’s Statutory Residence Test was required in order for the beneficiary’s pre-arrival planning to be effective.
- Modernising antiquated trust structures so that trustees can invest efficiently and reduce administrative costs.
- Advising an UHNW entrepreneur on the structuring of his worldwide assets and general succession planning, with a particular focus on his family settlements. His extensive personal assets, and those of the trusts which he has established, include investment vehicles, his family office, real estate, planes and a significant collection of art. Fiona was able to use her vast network of foreign lawyers to give the client a seamless, cross-jurisdictional service.
- Advising a UK resident non-UK domiciliary on structuring her financial advisory business whilst it was in its infancy, before significant growth, ensuring that the structure remained flexible enough to adapt to her business and personal aspirations for geographical expansion.
- Advising a non-UK family with very substantial industrial and real estate holdings on the establishment of a Bermuda PTC and trust structure; assisting with the relocation of its family investment office from Dublin to London and continued trusts support.
- Advising a successful UK entrepreneur with succession planning for his global assets, assisting with inter-generational discussions, lifetime giving, detailed letters of wishes, trust and will drafting.
