As UK inheritance tax rules expand and US policy evolves, advisers are reassessing how internationally mobile families should approach wealth, residence and succession planning.
Read moreHetal is a Partner at Edwin Coe with deep expertise in bespoke tax advice and leads the firm’s tax compliance and compliance checks offering. She is widely recognised for advising Global Indian families, combining cultural understanding with technical precision to deliver cross-border solutions. Hetal also works with institutional clients, including private banks and trust companies, providing training and strategic input on evolving tax legislation. Her specialisms include complex international tax structuring, pre-arrival and exit planning, treaty relief, and tax disclosures. Since joining in 2013 and becoming Partner in 2017, Hetal has built a reputation for clarity, responsiveness, and commercially sound advice.
1. Advised on diversification of business operations from South East Asia to Europe for an Indian entrepreneurial family
2. Involved advising on a joint venture with a UK corporate entity and structuring to protect clean capital, and provide a robust structure for investments into the UK, with a view to succession goals for the wider family (comprising of UK resident and non resident family members)
3. Advised on and regularised the historic personal tax position of the UK resident family member
4. Advised alongside Indian operating entity CFO, Indian tax and accounting firm, Indian legal counsel, Jersey based trust and corporate service provider
5. Matters considered:
a. Identify and propose an offshore structure that offer tax efficiencies for the joint venture, and can also ring fence any subsequent joint ventures
b. Advice on the on going tax position for UK resident family member, and wider non resident family with a stake in in the corporate structure
c. Consider anti avoidance legislation, substantial shareholding exemption and dividend flow through
d. Consider structure of putting the structure in funds to preserve clean capital
e. Review tax residency for family member with high UK day count since covid 19 pandemic, application of Statutory Residence Test, voluntary disclosure to HMRC regarding years of UK tax residency, claim for the remittance basis of taxation and/or treaty claims
f. Advise on settlement of offshore corporate structure into a discretionary trust for succession purposes
g. Business sponsorship licence for key workers in India
h. Trademark registration for UK entity
i. Corporate and secretarial services for UK entity
6. Successfully delivered project working across Edwin Coe‘s Immigration, IP, Corporate and Tax teams.
7. Providing on-going advice
The client was a UK resident non-domiciled individual. His father was a non UK resident family member. The proposed joint venture was being advised by another London law firm, and there was significant time pressure when the family sought alternate counsel due to dissatisfaction in service levels.
We were fortunate that Edwin Coe could assist across multiple work streams, and were assisted by the excellent work of the wider team.
As UK inheritance tax rules expand and US policy evolves, advisers are reassessing how internationally mobile families should approach wealth, residence and succession planning.
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