Helping your private clients achieve their aspirations with efficiency.
Whether your clients are successful entrepreneurs, high-earning executives, or wealthy family estates, a comprehensive private client service just isn’t possible without expert tax advice.
Our holistic advisory service can assist in most private client scenarios, with estate planning, asset restructuring and wealth preservation as key areas of expertise.
Whenever we may be needed, OneE are here to help your clients realise their needs and aspirations, while helping you provide an indispensable service.
For more information about how our tax advisory service may be of benefit to your private clients, please call us directly on 01204 559914 or send an email to firstname.lastname@example.org.
Some examples of past work are detailed below:
Case study 1: Wealth Preservation
Following the meeting OneE were instructed to implement the structure. We first guided the client through the process of establishing an offshore discretionary trust for the benefit of his family members. A trust deed was drafted by in accordance with the client’s objectives, with OneE Trustees to act as trustee managing the wealth held on trust.
Once the trust was established the client was then advised on the transfer of land into the trust. Rather than gifting the land, with guidance from OneE the client instead opted to transfer the land in such a way that it would not be considered the making of a “settlement”. As a result of this, and other measures, the provisions that would typically tax UK-resident settlors on the income and gains of an offshore trust would not apply. The assets of the trust could thereafter be held in a tax-efficient environment, allowing wealth to grow with reduced liability to UK taxes (importantly, although outside of the net to UK capital gains tax, the trust was still subject to 10-yearly inheritance tax charges – the client considered this acceptable given the assets were now held outside of their estate).
The trustees thereafter managed the trust assets for the benefit of the family members, renting the land to local farmers and obtaining a healthy income. In due course, the trustees decided to pursue planning permission and dispose of the land, giving rise to a significant gain on disposal. Due to the offshore residence of the trustees, and the way in which the settlement was structured, no liability to UK capital gains tax was incurred on sale, allowing the entire proceeds to be retained. The proceeds were subsequently reinvested, by way of commercial investments, and also through the making of loans to family members.
We were thereby able to meet the client’s objective of setting in a place an efficient structure to preserve wealth for future generations.
Case study 2: Succession Planning
The clients owned several highly valuable properties in London, and were keen that any restructuring was tax-efficient, with particular concern for the large gains inherent in the properties due to their lengthy period of ownership.
The property rental business was thereafter conducted by the LLP, which offered a more suitable commercial structure for on-going business activities. Income was shared by the members in the proportions outlined in the partnership agreement (drafted by OneE in accordance with the client’s bespoke requirements and objectives).
Rather than an outright transfer to the LLP, the property business was sold at market value, with consideration for the sale left outstanding by way of a loan agreement. The benefit of this “IOU” from the LLP was gifted to the clients’ children, representing a gift of the value of these assets while control was retained via the partnership agreement.
Although the clients’ interest in the LLP continued to form part of their estate for IHT purposes, as a result of the debt due from the LLP to their children, the value of the clients’ partnership share was very low. This therefore had the effect of reducing the value of their estate – assuming the clients survived seven years from the date of the gift of the IOU, its entire value would fall outside their estate for IHT purposes.
Thus the clients achieved their objective of setting in a place a highly commercial arrangement to protect their wealth and pass onto the next generation the assets, while retaining control during their lifetime.
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