Private Client Law and Accounting 2025: The Best and Worst Rules for Wealth, Tax and Estate Planning
As the UK faces a potentially tax-heavy Autumn Budget and the US prepares for sweeping sunset changes to estate tax laws, top lawyers and accountants share which rules they praise, which they condemn, and what reforms could reshape private client work in 2025.
The private client world stands at a crossroads. In Britain, accountants and lawyers are bracing for the November Budget, with whispers of rises in inheritance tax, capital gains, and property duties. Across the Atlantic, the expiry of key provisions from the US Tax Cuts and Jobs Act (TCJA) looms at the end of 2025. As reported by leading accountancy networks, that “sunset” could halve the federal estate and gift tax exemption, pulling thousands more families into its scope.
For private client advisers, both in the UK and globally, this is a defining moment. The laws that govern wealth transfer, property and succession are not just fiscal rules — they shape how families plan, save and thrive. Below, leading experts in private client law and accounting share their candid views on the best, worst, and most curious aspects of wealth legislation today.
Global Perspective: Why Transfer Taxes Stir So Much Emotion
Joshua S. Rubenstein, Partner and Global Chair, Private Wealth, Katten Muchin Rosenman LLP (New York, USA). Based in New York, he advises international families on cross-border estate planning and fiduciary disputes.
“In terms of the Love Hate feature, forced heirship remains high on my list, but let’s confront the elephant in the room, who loves estate, inheritance and other death-time transfer taxes? On the one hand, no one likes working hard their whole life only to have to pay 40% or more of their net worth to the Revenue upon their death, It can force the sale of illiquid assets to pay the tax, and it raises very little revenue for the Fisc yet requires a lot of enforcement effort,
On the other hand, transfer taxes in fact have nothing to do with raising revenue, Rather, they are a policy-driven tax designed to discourage hoarding and to encourage the redistribution of wealth, It is a voluntary tax, which you can easily avoid by not hoarding and by voluntarily redistributing wealth, There is merit on both sides of the philosophical argument,
I think the trick is on the one hand to impose transfer taxes for valid policy reasons, but on the other hand to have meaningful nil bands, so it does not impact taxpayers who don’t have enough for themselves to be forced to give away assets in order to avoid the tax, The UK nil band of £325,000 is unrealistically low, while the US exemption from transfer taxes of $15 million ($30 million for a married couple) is much more realistic.”
Rubenstein sets the tone for the discussion, contrasting fairness and policy intent in transfer taxation.
Balancing Fairness and Complexity in UK Law
Matthew Briggs, Partner, Boyes Turner (Reading, UK), advises high-net-worth families on wills, trusts and succession planning, collaborating closely with accountants and tax advisers.
“Private wealth law is at its best when it balances fairness, clarity and flexibility. Testamentary freedom in the UK remains a standout best law, it respects individual autonomy and avoids the rigidity of forced heirship regimes, giving families scope to plan in ways that reflect their values,
By contrast, the UK’s inheritance tax regime is often cited as a worst law, the nil-rate band has been frozen for far too long, dragging more families into its scope, while the rules themselves are overly complex and riddled with exceptions, The result is a system that feels both inequitable and inefficient.”
Briggs’s remarks highlight how complexity and outdated thresholds have tilted the balance against fairness. As Trevor Warmington, Partner and accountant at Rawlinson & Hunter, observed in 2024, “IHT is by far the most hated tax, a second dip on net income.”
Inheritance Tax Frustrations: Families Under Pressure
Amy Lane, Partner, Private Client, Gunnercooke (London, UK) advises entrepreneurs, family offices and their accountants on inter-generational planning and gifting strategies.
“ IHT remains one of the most hated taxes, The money taxed on death has already been taxed once and the raids are completely impractical, If you take a higher-rate taxpayer, they have paid 45% on that income, which then gets taxed at 40% when they die, That’s an effective rate of 85%,
There’s mumblings about introducing a lifetime allowance on gifts, If the Government did that, the housing market would collapse without the Bank of Mum and Dad or grandparents, If families cannot help each other out without these excessive controls on already taxed income, what’s the point in working hard and saving?”
Lane’s perspective captures a wider public sentiment. For accountants and wealth advisers, her comments resonate with clients who feel penalised for saving.
Stamp Duty Land Tax: A Love-Hate Relationship
Sean Bannister, Head of Tax, Edwin Coe LLP (London, UK), is a senior tax accountant and adviser to ultra-high-net-worth clients on UK and cross-border taxation.
“ Whilst there is much to spark passion in the UK tax system, whether it be the broad and ill-defined scope of our anti-avoidance legislation or the continuing transfer of responsibility from the state to the individual, the tax that I hold closest to my heart is SDLT,
What started as a relatively simple transactional tax that could be dealt with by your local conveyancer has become a labyrinthine mess that needs specialist advice in almost all circumstances,
It also tends to be expensive, and what greater parallel could one draw to love itself.”
As James Quarmby, Partner at Stephenson Harwood LLP (London, UK), warned last year, SDLT has “passed the point on the Laffer curve,” proving that higher rates can hurt both taxpayers and the Treasury.
The Worst Tax Ever?
James Quarmby, Partner, Stephenson Harwood LLP (London, UK) is a leading UK tax lawyer and commentator who works closely with accountants, trustees and wealth managers.
“ Stamp Duty Land Tax, once just plain old stamp duty, was levied at 1% on property transactions and, whilst a nuisance, it didn’t really make much difference, Fast-forward 30 years and our top rate of SDLT is now 19%, almost as much as VAT.
At this ludicrous rate it simply kills the transaction, even at the lower end of the market, SDLT penalises landlords who face a second-home surcharge of 5%, This restricts supply and drives rent inflation,
In a dynamic economy such as ours, any barrier to moving home is bad news, It stops people moving for work, trading up or down, and distorts the market, It is without doubt the worst tax ever and should be consigned to the dustbin of history.”
Quarmby’s critique underscores how SDLT has evolved from a mild inconvenience to a genuine economic barrier.
When Policy Becomes Panic
Neil Hoolahan, Grant Thornton Channel Islands (St Helier, Jersey). He is a senior tax accountant advising cross-border clients across the Channel Islands and UK.
“One from me would be badly thought-through, panic-driven, knee-jerk changes in legislation,
One example of this would, in my view, be the changes to the IHT treatment of pension schemes in the UK, these changes in the short term will increase revenue for the government but will likely lead to changes in behaviour toward saving for retirement,
In the longer term these changes will likely lead to increased demand and stress on publicly funded services, eroding the very benefit they seek to achieve.”
Hoolahan’s frustration mirrors Trevor Egan, Partner and accountant at Buzzacott, who said in 2024, “The personal tax return is very poorly constructed, the brave and once-in-a-generation solution would be to rip the whole thing up and start again.”
Offshore Simplicity: A Case for Fewer Laws
Alasdair Davidson, Partner and Notary Public, Bedell Cristin Guernsey LLP (Guernsey) offers an offshore viewpoint where simplicity is often the greatest virtue.
“ Perhaps I take a different approach… the abolition of these has greatly simplified aspects of life in Guernsey, I would love to complain about the unfair incidence of inheritance tax or punitive wealth taxes or pension grabs used to fuel government spending, but we don’t have those at all, perhaps the best laws are the absent ones after all?”
As Roy Campbell, Senior Partner at Druces LLP, noted in 2024, “Many laws are not designed to encourage foreign investment, Brexit is also making movement within Europe difficult.” Davidson’s perspective is a reminder that simplicity, not volume, is often the key to an effective legal system.
Asia’s Perspective: Transparency in Succession
Patricia Woo, Partner and Co-Head, Global Family Office Team, Squire Patton Boggs (Hong Kong) advises Asia-Pacific families on governance and succession planning, bridging legal and accounting practice.
“I would like to share the contrast between availability of public access to probate applications and enduring power of attorney, both key succession-related documents and procedures,
Access to probate applications is not freely available during the legal process in Hong Kong, Once the grant has been issued, inspection of documents is generally not allowed unless there is good reason,
However, anyone can conduct a search for a registered enduring power of attorney at the Hong Kong High Court Registry for a nominal fee.”
Her comments highlight how procedural transparency varies sharply between jurisdictions — an issue accountants and lawyers alike face when managing multinational estates.
Small Jurisdictions, Big Lessons
John Rimmer, Consultant Advocate, Whittles (incorporating Advocate John Rimmer Limited) (Isle of Man). He has more than 30 years’ experience in trusts, foundations and probate litigation, often working alongside accountants on cross-jurisdictional audits.
“ As noted in last year’s Citywealth edition, controversial doctrines such as rule against self-dealing, remote person claims and gifts to carers often spark heated debate, The balance between protecting vulnerable beneficiaries and enforcing testamentary freedom is delicate, and in smaller jurisdictions the margin for error is slimmer.”
Rimmer’s experience reinforces that clarity and proportion matter as much in small islands as in global capitals.
Competitiveness and Capital: A Warning from Accountants
Michael Lewis, Partner and Accountant, EY Private Client Services (London, UK)
“Only the UK would have senseless rules which discourage the wealthy from bringing funds into the country.” Lewis’s earlier remark still captures the UK’s struggle to remain competitive as a global wealth centre, a theme echoed by both accountants and legal advisers.
Looking Forward: Budgets, Sunsets and Reform
With the UK Autumn Budget likely to tighten fiscal policy and the US preparing for reduced estate tax thresholds, accountants and private client lawyers agree that 2025 will be a pivotal year for wealth planning.
As reported by professional bodies, the American “sunset” of the Tax Cuts and Jobs Act could dramatically reduce the estate and gift tax threshold, while the UK may target inheritance and capital gains reliefs. Both developments make forward planning critical.
In a field where law and accounting intersect every day, our contributors remind us that the best private client laws enable planning, clarity and fairness — and that sometimes, as Guernsey demonstrates, the smartest rule is the one that quietly stays out of the way.
Key Takeaways
- The UK anticipates a tax-heavy Autumn Budget while the US faces changes to estate tax laws, impacting private client work.
- Experts discuss the best and worst aspects of wealth legislation, highlighting issues like inheritance tax and transfer taxes.
- Transfer taxes provoke strong opinions; some view them as necessary while others criticize their inefficiency and impact on families.
- Private client lawyers and accountants stress the importance of clarity and fairness in wealth planning amid upcoming reforms.
- Looking ahead, 2025 is seen as critical for wealth management due to potential tax changes in the UK and US.
Estimated reading time: 10 minutes
Joshua S. Rubenstein’s Citywealth Leaders List profile
Katten Muchin Rosenman’s Citywealth Leaders List profile
gunnercooke’s Citywealth Leaders List profile
Sean Bannister’s Citywealth Leaders List profile
Edwin Coe’s Citywealth Leaders List
James Quarmby’s Citywealth Leaders List profile
Stephenson Harwood’s Citywealth Leaders List profile
Neil Hoolahan’s Citywealth Leaders List profile
Grant Thornton’s Citywealth Leaders List profile
Alasdair Davidson’s Citywealth Leaders List profile
Bedell Cristin’s Citywealth Leaders List profile
Roy Campbell’s Citywealth Leaders List profile
Druces’ Citywealth Leaders List profile
John Rimmer’s Citywealth Leaders List profile
Whittles’ Citywealth Leaders List profile
Michael Lewis’ Citywealth Leaders List profile
EY’s Citywealth Leaders List profile
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