Dominic Lawrance, Partner
Dominic’s specialisms are tax planning for international clients, succession structures, tax regularisation and philanthropy.
Dominic’s specialisms are UK tax planning for international clients, succession structures, advice on English law trusts and trust drafting, tax regularisation and philanthropy.
He has been working in the field of private client law since 2002. He is particularly known for his work in advising UK resident, non-UK domiciled individuals (“RNDs”) on their estate planning and the structuring of their affairs to ensure tax-efficiency. These clients include US nationals resident in the UK. He has a wealth of experience in establishing offshore structures and in advising offshore fiduciaries on the governance of such structures.
Dominic has also advised private banks, investment managers and multi-family offices on their offerings to RND clients - what they need to do to attract and keep RND business, and how to ensure that their arrangements for RND clients are as tax-efficient as possible. Dominic is an experienced adviser on charities and tax-efficient philanthropy, and has established many charitable entities for his clients. Since 2011, Dominic has been a co-author (with tax barrister Giles Clarke) of one of the leading practitioner’s guides on the subject of tax planning for internationally mobile clients, Clarke’s Offshore Tax Planning. This substantial work is widely read by offshore trustees, wealth managers and tax advisers.
Dominic is admitted to practise in England and Wales.
- Has advised countless non-UK domiciled individuals on the steps they need to take prior to becoming UK resident. This includes identifying when they will become resident, possible steps to be taken to re-base assets, putting in place suitable account arrangements, identifying and disposing of unsuitable investments or “wrappers”, and funding the purchase of a UK property
- Has advised a great many RNDs on pre-deemed domicile planning. This includes assisting RND clients with the creation of protected settlements and offshore life bond trust structures, which can provide long-term protection of assets from inheritance tax, income tax and CGT. In such cases he advises on the intricacies of the protected settlements rules; on how to ensure that such settlements are not “tainted”; and on how such structures may be wound up tax-efficiently in the event that they cease to be useful, e.g. once the client has left the UK
- Has advised in a significant number of divorce cases where wealthy RND couples have wanted to ensure that the agreed financial arrangements would not give rise to unnecessary tax liabilities. Such cases frequently involve trusts or other entities
- Has assisted clients in a great many cases by establishing a charitable or “not for profit” foundation, and advising on the most tax-efficient way to transfer funding to it. Such foundations have included several “dual-qualifying” charities for US/UK donors
Dominic Lawrance quoted by Citywealth on the tax implications of crypto activities
As HMRC nudge letters arrive at the homes of crypto asset owners, how can UHNWs stay on the right side of HMRC.
Dominic Lawrance quoted by Spears on the taxing of cryptocurrency assets in the UK
In some circumstances, cryptocurrency-related activity may constitute ‘trading’ and may be subject to income tax, but this is rare.
Hugh Gunson, Dominic Lawrance and Catrin Harrison write for Taxation on the limits to HMRC’s power to require information from foreign domiciled taxpayers
Are there limits on HMRC’s power to require information from foreign domiciled taxpayers?
Information overlord? Are there limits on HMRC's power to require information from foreign domiciled taxpayers?
Hugh, Catrin and Dominic look at the decision in Perlman v HMRC. The latest decision where HMRC is challenging a taxpayer’s domicile
Tooth v HMRC: Getting to the Root of the Discovery Assessment Regime
Dominic Lawrance, Hugh Gunson and Catrin Harrison write for Tax Journal on Embiricos and the future of partial closure notices
A look at the Upper Tribunal's decision in Embiricos and the implications for those faced with a domicile enquiry.
Hoist with his own petard? Henkes v HMRC, and the lessons that can be learned regarding domicile enquiries
In recent years HMRC have shown a growing interest in challenging taxpayers on their claims to being foreign domiciled
Another fine mess: imminent changes to the IHT excluded property rules
The Finance Act 2020 will include some changes to the rules regarding ‘excluded property trusts’ in the inheritance tax legislation.
Another fine mess: imminent changes to the IHT excluded property rules call for urgent action by trustees
DAC 6: six types of ambiguity
EU Council Directive ('DAC 6') was passed in May 2018 and has been incorporated into UK law by the International Tax Enforcement Regulations
Dominic Lawrance and Elinor Boote write for Tax Journal on the ambiguity of DAC6
Deemed to fail: Fowler v HMRC
Now a Bit more certain: the legal status of Bitcoin
Dominic Lawrance writes for eprivateclient on HMRC's latest guidance on cryptoassets
Dominic Lawrance quoted in the Financial Times on the government’s proposal to narrow the focus of the new regulations on trusts
Trusts and transparency: the government's proposals start coming into focus
Dominic Lawrance quoted in the Financial Times on the impact of the Fifth Anti Money-Laundering Directive
Dominic Lawrance quoted in the Financial Times on a tax liability reduction case
Trusts and Transparency
The EU’s Fifth Directive on Anti Money Laundering (AMLD 5) will take effect from 10 March 2020.