Christopher specialises in advising private clients in relation to their estate planning needs, including wills, trusts and inheritance tax mitigation. His work includes the formation and restructuring of family trusts to achieve tax efficient succession planning, and advising owners of landed estates on inheritance tax mitigation, including maximising agricultural and business property reliefs, and advising on capital gains tax. He also advises on pre-sale tax planning for shareholders in private trading companies.
He has advised non-UK resident trustees on tax efficient distributions to UK resident beneficiaries, and has advised on residence and domicile issues for private clients coming to or leaving the UK, including obtaining favourable domicile rulings from HMRC on behalf of private clients.
He advises institutional trustees on all aspects of trusteeship, including trustees' duties and powers, claims by beneficiaries and tax planning, and frequently advises pension scheme trustees on the creation of trusts to hold death benefits.
Christopher acts as a trustee for a number of family trusts and is a member of the Society of Trusts and Estate Practitioners (STEP).
Examples of experience include advising:
- A landed estate client on restructuring of the ownership of the mansion house on the estate, allowing the senior family member to continue to occupy whilst overcoming IHT reservation of benefit issues. The house was of great strategic value to the family, and Christopher devised and implemented the tax planning strategy to protect it from IHT
- The newly appointed trustees of an offshore trust/company structure on a review of the structure and in particular the tax implications of capital distributions being made to a UK resident beneficiary through the use of a share structure which ensured that receipt of those distributions did not give rise to an income tax liability. Christopher also advised on the tax implications of migrating the main holding company to a new jurisdiction. This was all vital to ensuring that the offshore structure remained fit for the family's purpose
- Restructuring a family trust to allow gifts of shares in the settlor's business to be made without triggering a substantial liability to capital gains tax
- A family with very substantial business and farming interests on inheritance tax planning through the use of wills, including taking advantage of business and agricultural reliefs, and ensuring that the assets were held on flexible trusts to enable provision to be made for future generations on a flexible basis
- In connection with creation of a trust fund to hold various pension and life insurance death benefits payable on the death of a senior employee of a listed company. The funds needed to be held in trust for the young children of the deceased employee in as tax efficient a manner as possible. Christopher was able to agree favourable inheritance tax treatment of the trust fund with HMRC.
"I find his technical abilities to be faultless. His written communication is of particular high quality."
"Always very technically brilliant. He is my go-to guru."