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Partner, Head of International Private Wealth
Specialism: Lawyers Tax Corporate and Regulatory
Location: London, England
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Average client size: Over £25 million
Fixed fee offering: Yes
Number of offices globally: 1-5
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Recent cases include:
Before his death, our client was a world-renowned art collector with a collection that in value terms is essentially priceless (quoting Bonhams Head of Cultural Heritage and Taxation). RadcliffesLeBrasseur had acted for him and his family for over 30 years dealing with international taxation and estate planning including structuring in Panama and Switzerland through trust and company entities. The family is one of the most prominent and wealthy in Europe.
Before the art collector passed away, Jonathan Shankland had amended his final estate planning and Will in October 2015. The estate was vast and complex, comprising property over many jurisdictions, private business interests in a long-established family company, interests in numerous offshore trusts and companies as well as significant cash holdings.
During 2018 Jonathan and his team completed the administration of the estate including final tax clearance from HMRC for an estate that spans multiple jurisdictions and hundreds of millions of pounds of assets. The team dealt with the winding up of two offshore trusts and an offshore company holding family assets linked with the estate and in conjunction with the Trustees in Switzerland. The team dealt with the complex implications of the Finance Act
2017 (Part I and II) changes to the taxation of offshore entities and devised a suitable tax effective mode of unwinding the structures in the most tax effective manner for beneficiaries across a number of countries each with their own additional tax considerations. We reported to HMRC for ATED CGT and Non-Resident CG for UK property of important heritage value to the UK (Richmond Palace, Old Palace Yard).
The team dealt with the heritage gifting from the estate of prominent works of art.
Jonathan is now instructed by the wider family, advising on international tax planning and structuring. The family is advised by RadcliffesLeBrasseur’s International Private Wealth team, led by Jonathan Shankland, including residential property advice, immigration in relation to Brexit and UK right to remain.