Tax issues on stake sales and investment into managers: structuring, pitfalls and steps to take now
About
Richard advises on all aspects of estate planning and personal taxation and focuses on cross-border tax advice. Many of his clients are individuals with a presence in multiple jurisdictions, and who originate from jurisdictions in Europe, North America and the Middle East.
Richard also advises on the establishment and management of international asset-holding structures, focusing both on international taxation and asset protection. He has extensive experience in planning for international families, entrepreneurs, finance professionals, and regularly advises clients in relation to complex HMRC enquiries and disputes relating to tax or succession matters.
Richard advises individuals, trustees, family offices and investment managers in relation to the tax treatment of complex structures and investment products, and has advised a number of banks and investment managers on the structuring of their investment platforms and the selection of appropriate investments for non-UK domiciled clients.
He spent six months in New York on secondment to a leading New York law firm, where he worked alongside US lawyers, gaining an understanding of US tax, trust and estate planning that assists him in advising US clients who are resident in the UK or own UK assets.
Richard is a regular speaker at wealth planning seminars and events and has written for Trusts & Trustees.
Experience
- Acting for a Guernsey trust company on a long-running case which raised questions of private international law and trustee liability. Judgment in favour of Macfarlanes’ client was given by the Judicial Committee of the Privy Council in 2018.
- Advising partners in a private equity business on the structuring of carried interest and co-investment arrangements in a manner which takes account of UK and Italian tax considerations.
- Advising a non-UK domiciled individual in respect of an investigation conducted by HMRC, which covered complex points of international taxation.