Alice Wilne

Alice advises a wide range of UK domiciled and non-UK domiciled individuals and their families, as well as trustees.  

Alice has expertise in advising on:

• Wills and succession planning arrangements;
• tax and estate planning involving UK resident and non-UK resident trusts;
• the English law concept of domicile, the statutory rules which determine UK tax residence and the implications of domicile and tax residence; and
• a wide range of other matters for individuals typically involving complex UK tax issues.

Alice joined the firm in 2004. She enjoys building and maintaining long-standing client relationships and acting as a trusted adviser to clients and their families. She regularly works collaboratively with clients’ accountants and other professional advisers, including in other jurisdictions, to coordinate and dovetail their advice and estate planning. She also enjoys working together with other teams within the firm where a client’s needs extend outside her own expertise.  

Wills and succession planning
Alice assists clients to put in place bespoke Wills, often involving matters where the client’s succession planning needs are complex e.g. due to the particular family circumstances, the application of foreign succession laws and/or US tax exposure.  Alice also advises clients on their lifetime succession planning arrangements, including the use of trusts and alternatives to trusts, including family governance arrangements, for estate planning purposes.

Domicile
Alice advises clients on the English law concept of domicile and assists clients with reviewing its application to their particular personal situation.   This includes advising both UK resident clients with non-UK domiciles of origin and non-UK resident clients with UK domiciles of origin.  Alice also advises individuals on the implications of their domicile status for succession law and UK tax purposes.

Trusts
Alice advises clients on the creation of trusts, as well as changes to and distributions / benefits from trusts.  Alice also assists families and trustees with reviewing long-running trust structures (whether UK resident or non-UK resident), e.g. to advise them on the UK tax implications of splitting a single trust structure between two sides of a family, or to wind up the structure tax efficiently, or to simplify and/or bring onshore a complex offshore trust.
 

Tax
Most aspects of Alice’s work will involve tax advice in some form or another, including advice on the following:  

• the scope of UK inheritance tax, including the availability of any exemptions or reliefs, lifetime gifting and the operation of the complex “gift with reservation of benefit” rules;
• the creation of trusts by non-UK domiciled individuals prior to becoming deemed domiciled for UK tax purposes and the related “excluded property” and “protected settlements” rules;
• the UK tax regime applicable to UK residential property and related loans and collateral arrangements, including advising on new property purchases and reviewing existing property holding structures and assisting with unwinding these where they are no longer tax-efficient;
• the application of the UK’s statutory residence test for determining UK tax residence for clients wishing to relocate to or from the UK, including the scope of UK taxation for UK resident or non-UK resident individuals and related matters, as well as any applicable double tax treaties;
• the rules relating to the remittance basis of taxation for UK resident, non-UK domiciled individuals and how to structure banking and investment arrangements in order to maximise the benefit of this regime, including the operation of the “mixed fund” rules for current and former remittance basis users;  
• the characterisation from a UK tax perspective of investments and foreign law entities;  
• the disguised investment management fees (DIMF) and carried interest rules, with particular expertise in matters involving non-UK domiciled clients and offshore structures; and
• regularisation of tax affairs, where an individual has inadvertently made mistakes with their UK tax filings.