About
Since beginning my career in private client law in 2002, I have become particularly recognised for advising successful internationally mobile individuals who are currently UK resident or are planning on moving to the UK. I also have extensive experience with the creation of non-UK resident structures and solutions for the holding and management of wealth. I enjoy solving complex problems for our clients and transforming seemingly unsolvable problems into manageable ones.
Together with my colleague Catrin Harrison, I write 'Clarke’s Offshore Tax Planning', a comprehensive guide to this area of law, which is widely recognised as a key resource by other UK tax advisers, wealth managers and offshore trustees.
I am admitted to practise in England and Wales.
Experience
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Over my career I have advised numerous non-UK domiciled individuals on the steps they need to take prior to becoming UK resident, and on their tax planning more generally. This includes identifying when they will become resident, possible steps to be taken to re-base assets before becoming resident, putting in place suitable arrangements to preserve clean capital, and identifying unsuitable investments or problematic structures.
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I have also advised many UK resident foreign domiciled clients on pre-deemed domicile planning. This includes assisting them with the creation of protected settlements and offshore life bond trust structures. In such cases, I have advised 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 if they cease to be useful.
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I have advised in a significant number of divorce cases where wealthy UK resident foreign domiciled 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.
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I enjoy grappling with new problems and over the years, have advised on esoteric matters such as the UK tax treatment of usufructs, executive jet ownership arrangements, structures for the holding of film music royalty rights, and structures for the holding of cryptocurrencies.
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In many cases I have advised on the application and interpretation of double taxation treaties, and planning based on treaty reliefs.
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I also have experience of contentious matters, including HMRC enquiries and applications to court to seek rescission of gifts and rectification of trusts.
