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.
Read moreSean Bannister is a Chartered Tax Adviser and Head of Tax at Edwin Coe. He advises high-net-worth individuals, families, and entrepreneurs on complex UK and international tax matters, including structuring, succession planning, and dispute resolution. With expertise in cross-border issues and non-resident investment, Sean is trusted by family offices, trustees, and professional advisers for clear, pragmatic guidance where tax, reputation, and strategy intersect. Known for his calm, commercial approach, he ensures tax solutions support long-term objectives. Leading a multidisciplinary team, Sean delivers integrated advice tailored to each client’s unique circumstances.
1. Advised on re-structuring of international trading and non-trading corporate structure prior to change in legislation in Singapore to maintain efficiencies and create overlying succession structure (non-UK discretionary trust).
2. Advised alongside UK big 4 accounting firm, Canadian and Singapore counsel, private bank and Jersey based trust and corporate service provider.
3. Received instructions in the second week of December with a completion date of 31 December in light of Singapore legislative change.
4. Matters considered:
a. Review of accounting advice on application of certain anti-avoidance legislation as applied to the structure.
b. Consideration of implications of commercial re-structuring already taken as relates application of relevant anti-avoidance legislation post delivery of advice at a.
c. Consideration of steps being taken to achieve pre 31 December re-structuring on application of anti-avoidance legislation.
d. Review and changes to step-plan to achieve pre 31 December aim, including form of settlement on to structure.
e. Advice on the on-going tax position of the structure for:
i. Settlor
ii. Beneficiaries
iii. Trustees
iv. Directors of holding company
f. Input and review of corporate agreements to give effect to revised step plan.
g. Advice on document execution and Stamp Duty Reserve Tax and review of advice on UK Stamp Duty more generally.
5. Successfully delivered project working across Edwin Coe‘s Private Client, Corporate and Tax teams.
6. Providing on-going advice on post 31 December parts of the step plan.
The client was a UK resident non-domiciled individual. The trading group held both trading and non-trading assets and had recently received third party private equity investment meaning that there were multiple stakeholders with their own requirements, and significant time pressure to deliver the project. We were fortunate that Edwin Coe could assist across multiple work streams, and were assisted by the excellent work of the wider team.
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.
Read more
As the world globalises, conducting business can no longer be contained within one country. Citywealth speaks to experts on cross-border giving, taxation and US/UK wealth planning to understand the challenges faced by those building bridges for their cross-border clients.
Read more
