Tax issues on stake sales and investment into managers: structuring, pitfalls and steps to take now
About
Michael advises international individuals, trustees and family offices on tax, structuring and succession planning.
His clients include entrepreneurs, asset management executives, family offices and trustees. Almost all his work has a complex tax background and a strong cross-border element.
He has extensive experience advising international clients coming to the UK for the first time on pre-arrival planning and structuring for the longer term in the UK. He advises existing UK residents on navigating changes to the UK’s tax rules, as well as clients elsewhere looking to invest in the UK or with only minimal links to the UK on their family succession structuring.
He advises on establishing and running asset holding structures, bespoke family funds and family offices. He often works in tandem with advisers elsewhere to balance competing tax and practical demands in multiple jurisdictions, providing a consolidated cross-border service for clients.
Michael leads the firm’s Immigration practice, working with our specialists to provide advice to individuals and corporates on a range of immigration and nationality matters.
Michael co-hosts Macfarlanes' long-running cross-border planning seminars in Geneva and Zurich three times a year and has a particular focus on clients with a Swiss connection and the team's relationships with Swiss advisers, as well as a broader emphasis on matters with a European nexus.
Michael is a member of the Chartered Institute of Taxation.
Michael sits on the steering group for our Pride staff network, a forum for networking and peer support between LGBT+ staff and allies.
Experience
- Acting as long term counsel to a UK resident billionaire family, including innovative fund structuring to adapt to changes in the UK tax rules, advice on an HMRC enquiry, structuring for high-value asset purchases and funding family members outside the UK, as well as ongoing ad hoc queries about complex investments, family office planning and governance.
- Advising a Scandinavian founder on innovative planning to take advantage of the UK's FIG regime and double tax treaties, as well as consolidating and safeguarding his existing structures for the long term, both from a UK perspective and in his home jurisdiction.
- Succession planning for a Swiss resident family, including the establishment and maintenance of trusts for the benefit of UK and US resident family members working in tandem with Swiss counsel, complex partnership planning for simplified US reporting and changes to future-proof the structures from a Swiss perspective.
- Advising a UK resident asset manager on an exit plan from the UK and implementing complex changes to his existing structures and business interests with overseas counsel to take account of both Italian and US tax imperatives, as well as advising on longer term succession planning and philanthropic intentions.
- Advising a long-term UK resident family on changes to UK inheritance tax and establishing a UK based family office to invest family wealth efficiently and supervise business and personal interests.
- Working with German and US counsel on an individual’s complex worldwide estate planning to defer exposure to UK inheritance tax and safeguard succession to family company shares, including an analysis of how UK taxes apply to a range of civil law concepts.