Alice Wilne

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 works with clients to put in place bespoke Wills, often involving matters where the 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. 

Trusts
Alice advises clients on the creation of trusts, as well as changes to and distributions / benefits from existing 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 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;
• exposure to UK inheritance tax, including the application of the “long-term resident” rules introduced by Finance Act 2025;
• the application of the “qualifying new resident” (QNR) regime for individuals in their first four tax years of UK residence;
• the rules relating to the remittance basis of taxation and the impact of the changes introduced by Finance Act 2025 for UK resident individuals who previously benefited from the remittance basis regime;  
• estate planning involving assets qualifying for Business Property Relief and/or Agricultural Property Relief and exemptions for charitable gifts, both during lifetime and on death;
• the characterisation from a UK tax perspective of investments and foreign law entities; 
• the disguised investment management fees (DIMF) and carried interest rules; and
• regularisation of tax affairs, where an individual has inadvertently made mistakes with their UK tax filings.

UK / Italian cross-border planning
Alice also works regularly with her Italian qualified colleagues on UK / Italian cross-border tax and estate planning and has particular expertise on the UK / Italy double tax treaties and the UK tax treatment of usufructs.