Representative Matters
- Advised US citizen client in connection with coordinated planning to minimize exposure to dual income and estate/inheritance taxation in the US and in UK in light of the client’s extensive and intertwined business and holding company structures and risk of UK long term residency under UK income and inheritance tax regime.
- Advised multi-jurisdictional European client on (i) company structure to hold and monetize the client’s worldwide intellectual property, (ii) tax treatment and reporting of certain personal property assets and on structure to minimize future tax burden, and (iii) structuring and implementation of offshore trust structure to administer and preserve the client’s assets for future generations of descendants.
- Advised client regarding a pre-immigration plan designed by other firm and the associated US income tax risks. Provided advice on restructuring plan to achieve desired tax results and ongoing estate planning considerations. Provided lead counsel regarding obtaining a tax insurance policy to manage tax risks.
- Represented the beneficiary of 14 foreign trusts primarily located in UK and the Channel Islands with ties to California, served as co-counsel with local jurisdiction in drafting a multi-jurisdictional cohabitation agreement, advised on US estate tax and foreign trust income tax advice in relation to the tax exposure of the client, individually, and the non-US trusts created for her benefit if she becomes US tax resident, and worked with the client’s family office to address the most protective and tax efficient structure to hold US situs assets acquired by client.
- Provided tax advice regarding the structure of the sale of a Bahamian island ultimately owned by a US family through a Bahamian company and wealth planning advice related to the sales proceeds and ongoing succession planning advice for certain retained plots on the island.
- Advised client with jurisdictional ties to Gurnsey and Sweden on the domestication of a foreign grantor trust structure, significant corporate reorganizations of the underlying trust assets, income tax optimization, life insurance integration and basis management, as well as personal estate planning and estate tax mitigation strategies.
- Advised non US citizen surviving spouse in multi-jurisdictional post-death trust and estate administration across the US, Australia and New Zealand, including issues relating to coordinating the management of ongoing business entities all three jurisdictions, funding and supervising the development of a residential property in Australia, managing the disposition of assets situated in each jurisdiction, and addressing the US income and estate tax consequences of the deceased spouse’s assets.
- Represented the senior generation of a Swiss family in connection with the structuring of a Liechtenstein foundation to hold interests in non-US holding companies for the ultimate benefit of a child who is US tax resident.
- Represented the senior generation of a Belgian family in addressing the US income, gift, and expatriation tax implications of the gift of a bare interest in the certificates of a Dutch stichting administratiekantoor holding interests in a multi-tiered structure involving holding companies and operating companies in the US and throughout Europe.
