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International Wealth Structuring

At Charles Russell Speechlys, we advise international individuals, and their trustees and other advisers, on the establishment and administration of asset holding structures for their wealth, and on the increasingly complex cross border tax issues and reporting requirements that affect them. 

Much of our work is multi-jurisdictional, acting for families with family members, family offices and assets in multiple jurisdictions. Structuring can often go beyond conventional trusts and foundations and include, for example, private funds, cell companies and bespoke life insurance.

In relation to the UK, the tax rules have historically been designed to be attractive to wealthy international individuals both to reside and to invest in assets such as real estate. However those tax rules are increasingly complex, and have been changing at a bewildering pace. The UK remains an attractive place for international private clients to reside and acquire a home, but it has never been more important to take detailed professional advice before coming to the UK or acquiring a property. Waiting until after arrival or acquisition will now usually mean leaving it until too late. 

We are particularly noted for our work and solutions where conflicting tax and legal regimes affect international families and their wealth structures. This is highlighted where US taxation issues are involved: as US citizens and their estates are taxed wherever they reside in the world, very complex issues arise. The international drive towards tax compliance and global reporting has also seen an increased demand for the “onshoring” of wealth structures: frequently we advise on the use of Luxembourg and other EU jurisdictional structures in order to optimise the use of tax treaties or avoid jurisdictional blacklists.

In recent years there has also been a growing need to take proactive steps to protect personal, business and family wealth from the impact of matrimonial breakdown, succession disputes and appropriation of assets by foreign governments. This is often done through the use of trusts and similar asset-holding vehicles. The choice not only of vehicle but also jurisdiction is vital as is a deep understanding of the family and business governance issues involved. A fluid international market for business leaders and entrepreneurs, along with continuing migration as a result of political change, has fed clients' desire for international tax and legal support in countries with sophisticated financial systems.

As a full service firm, we can provide a full range of services to the international private client: not just “private client” advice on succession, tax, estate planning and property transactions, but we also draw on the expertise of our colleagues in the Family, Corporate, Real Estate, Employment and Dispute Resolution teams to provide a comprehensive and seamless service to our international private clients.