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Alice Wilne, Partner

Alice specialises in advising UK and international individuals, trustees and private banks in relation to UK tax and estate planning.

Alice Wilne, Partner

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Service:

Private Client

Summary

Alice regularly advises trustees and beneficiaries, often where assets are held in complex structures. This includes advice on the most appropriate way to provide financial assistance to beneficiaries, taking into account tax-efficiency and wealth protection concerns. 

Alice also advises trustees of a number of long-established family settlements, including providing assistance with restructuring how assets are held and varying existing trust provisions in the light of prevailing family and tax considerations and advising on appropriate tax and succession planning.

For international clients, Alice advises on domicile and the remittance basis of taxation.  She has particular expertise advising on the tax treatment of complex offshore corporate structures and the availability of ‘motive defences’ to tax charges under anti-avoidance legislation.

In addition, Alice has wide experience advising private banks on their banking and investment offering to their clients, including the characterisation from a tax perspective of particular kinds of investments and their tax treatment for remittance basis users.

Alice also has particular expertise advising investment managers on the complex tax regime which applies to the “carried interest” they hold in the investment funds which they manage.

Experience highlights

  • Advising clients in relation to the UK tax regime applicable to UK residential property and related loans, including reviewing existing property holding structures and assisting with unwinding these where they are no longer tax-efficient.
  • Advising clients with foreign domiciles and/or assets in a number of jurisdictions on their Wills and succession planning arrangements, including the implications of the EU Succession Regulations and on matters with a US element.
  • Advising on the availability of entrepreneur’s relief and business property relief in relation to family businesses, including in the context of estate planning to pass part of the business to the next generation.
  • Advising clients moving to the UK on pre-immigration tax-planning, including the application of the statutory residence test and how to structure their banking and investment arrangements to maximise the benefit of the remittance basis of taxation.
  • Advising on the relative merits of family investment companies as compared with personal ownership and traditional trust structures in the context of succession planning, from a tax and wealth protection perspective. 
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