Tax issues on stake sales and investment into managers: structuring, pitfalls and steps to take now
About
Sam advises high-net-worth individuals, trustees of non-UK trusts, family offices and other private client service providers.
His work has a significant international element, with most of his work involving cross-border tax, estate and succession planning and wealth structuring.
Sam’s work involves advising trustees and families on major international trust and corporate restructuring, advising entrepreneurs on structuring their business and personal interests and working on complex cross-border succession planning.
He has extensive experience advising on the interaction between a number international tax regimes, with a particular focus on the US and South Africa, as well as a number of other jurisdictions.
Sam has developed specialist knowledge of the UK’s multiple transparency regimes, including in particular the Register of Overseas Entities and the Trust Registration Service.
Experience
- Advising the trustees of a complex web of family trusts on structuring, day-to-day administration and the UK tax treatment of the trusts.
- Advising the trustees of family trusts with a high-value international asset portfolio on a complex trust restructuring involving significant cross-border tax considerations, including the impact of UK/US Double Tax Treaty on the proposed restructuring.
- Advising individuals on UK estate planning, including for new arrivers to the UK, long-term resident individuals and individuals leaving the UK.
- Providing ongoing advice to a family office in relation to family members who are resident in the UK, US and South Africa.
- Advising on the tax consequences of gifting valuable property to family members.
- Advising individuals and trustees on the application of the UK’s anti-avoidance regimes to complex international structures.
- Advising on the application of the UK’s various transparency regimes to complex international structures involving companies, partnerships and trusts.