Jennifer Smithson Partner

Partner

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Jennifer advises on all areas of personal tax and succession planning, with a particular emphasis on cross border tax advice, especially with a US or French aspect.

Jennifer also advises on the establishment and management of international asset-holding structures, has experience in planning for entrepreneurs, fund managers and senior executives, and regularly advises clients in relation to complex HMRC enquiries.

In 2013 Jennifer spent six months in New York on secondment to a large international private bank. There she worked alongside US and international wealth advisors on cross-border planning issues, gaining an understanding of US tax, trust and estate planning that assists her in advising US clients resident in the UK.

Jennifer advises individuals, trustees and investment managers in relation to the tax treatment of complex structures and investment products. She has extensive experience on advising in relation to family office structuring for both UK resident and non-UK resident families.

Jennifer is a regular speaker at wealth planning seminars and events and has contributed to a number of articles relating to the FATCA and Common Reporting Standard automatic information exchange regimes.

Expertise

Recent work

International trust structuring

Co-ordinating the unwinding of multiple family trusts holding a majority stake in a private family trading group worth over £3bn. The project included an application to the Guernsey Court to approve the distributions, negotiating with the trustees and their advisors, and implementing a significant re-organisation of the trading group in connection with the distributions.

Multi-jurisdictional and multi-generational family

Advising the family office of a large, multi-jurisdictional and multi-generational family, with significant trusts managed from the Isle of Man. This has included an annual review of the trust tax pool calculations and ensuring that these are appropriately declared where relevant in individual beneficiaries’ UK tax returns.

Cross-border estate planning

Assisting a UK resident, dual French/Swiss national with US citizens among his descendants in relation to his cross-border estate planning. The project included liaising with advisors in France, Switzerland and the US to determine what succession law would apply to the individual’s estate, and structuring accordingly. The project involved ensuring that assets could be retained in a single family co-investment vehicle, while taking into account the differing residence and tax statuses of the client and his children.

Family office creation

Developing a family office structure based in the UK to manage the investments of a UK resident non-UK domiciled individual, held through family trusts, working closely with colleagues in the tax and financial services groups in relation to the VAT, partnership tax and regulatory aspect of the project.

Advice to private banks

Regularly assisting the tax departments of international private banks advising in relation to the UK tax treatment of investment products, and structuring investment portfolios for UK resident non-UK domiciliaries.

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