Recent assignments include:
International Corporate Tax
- lenders picking up foreign tax credits for tax paid by the borrower
- double dipping of interest expenses
- avoiding CFC type rules to earn tax-free interest income
- IP owners earning tax-free royalties at home without heavy foreign withholding taxes
International Personal Tax
- overseas assets held by a family remaining outside their country’s tax net
- tax-free profits from the sale of shares
- avoiding tax on share option gains for mobile executives
- non-UK income and capital gains being only taxed on the remittance basis
UK Tax
- avoiding UK income (on all classes of income) and capital gains taxes
- keeping the UK tax rate to no more than 22% for UK trading profits
UK Outbound Tax
- setting up businesses abroad
- UK pension fund busting ie tax-free lump sums in cash from pension funds
- borrowing against UK retained property to buy another one abroad, with tax deductible interest
- mitigating UK inheritance tax on retained UK assets
