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Specialism: Lawyers Estate Planning
Company: Baker McKenzie
Location: Geneva, Switzerland
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Average client size: £5 million - £25 million
Fixed fee offering: No
Number of offices globally: More than 5
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Recent cases include:
Lead associate on a cross-border succession which involves international tax, trust and private international law questions arising from the management and distribution of an estate with assets worth +15 million, including real and personal property located in 6 jurisdictions. Significant assignments for this matter in the past 12 months include the liquidation of the decedent’s matrimonial property regime 10+ years after the divorce decree had first been ordered, and the restructuring of the decedent’s offshore (non-US) trust so that it can best serve the tax and long-term estate planning objectives of the US citizen beneficiaries of the trust.
Advised a US discretionary beneficiary of a number of foreign trust structures with regard to the tax treatment of distributions and payments from the trust structures (including, underlying offshore entities owned by the foreign trust), as well as US information reporting and FATCA obligations associated with the entities. Our advice has required liaising with counsel and trustees in several jurisdictions in order to obtain the most appropriate tax planning result for the client, considering both the original goals of the settlor as well as the needs and requirements of the US beneficiary.
Advised on a significant US tax regularization for various family members owning an asset management company and multiple real estate properties in Switzerland. The regularization involved complex questions of US tax law as well as Swiss and French family law and tax law. We have also provided advice in connection with US expatriation and relocation planning for certain family members.
Counselled the trustee of a non-US trust with US beneficiaries on the US tax consequences of deploying +USD 500 million in premiums across ten separate insurance policies, including the revision of private placement life insurance policies and related documents to customize them to the trustee’s needs along with drafting a legal opinion discussing the application of US federal tax laws of each insurance policy type to our client’s specific circumstances.