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 high profile
international family on the acquisition of an extremely high value UK
asset. Included advising on the establishment of two Jersey discretionary
trusts 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 the purchase of
corporate vehicles holding high value residential property.
- 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 changes to the UK’s taxation rules
relating to settlors of non-UK trusts who have since become deemed UK
domiciled.
- Working closely with the
trustees to identify the source of funds 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.
- Pre-arrival planning for
multi-national family moving their home and businesses to the UK.
Including property purchase, immigration (for family and staff), corporate
tax implications of changing the tax residence of companies and corporate
governance of companies remaining outside the UK.
- Provision of expert
succession law and tax advice in contentious probate and property matters.
Our Private Wealth expertise
Our Private Wealth team
