Tax issues on stake sales and investment into managers: structuring, pitfalls and steps to take now
About
Sarah advises on a broad range of UK and cross-border tax matters, specialising in group and international tax advice, complex reorganisations and demergers, and early stage tax disputes.
In particular, Sarah works closely with our Private Client group advising UK and international family offices, privately-owned businesses and their owners on a range of tax issues including structuring assets and investments, reorganisations, returns of value, family office creation, succession planning, governance, and multi-jurisdictional tax risk management.
Sarah has advised on a number of high-value tax disputes including in relation to transfer pricing and partnership tax issues.
Sarah also advises private capital clients in relation to the tax treatment of cross-border asset management groups and fund carried interest and co-investment interests.
Sarah is a Chartered Tax Adviser and a member of the Chartered Institute of Taxation (CIOT).
Experience
- Advising privately-owned international groups on managing corporate tax residence and permanent establishment risks and establishing associated governance guidelines.
- Advising privately-owned international groups on reorganisations for the removal of group entities in the UK and overseas.
- Advising on a full-scale UK tax review of the group and on the relocation of key UK executives to newly established European offices.
- Advising on the group and employment tax consequences of the founder resuming UK tax residence in respect of the international corporate group and various investment holding structures.
- Advising on the establishment of an offshore unit trust investment holding structure for the family.
- Advising on the corporate and employment tax consequences of private asset holding structures including trusts, partnerships and companies.