UK Non-Doms: UK US Planning for Current and Upcoming UK Non-Domiciled Taxpayer Regimes

Mr. Warshaw has nearly 40 years of experience as a U. S. estate planning and tax lawyer. He currently represents U. S. and non-U. S. high net worth individuals, families and companies on a wide range of personal and business tax matters, especially in connection with cross-border income and estate tax planning and compliance in the U. S. Mr. Warshaw is admitted to practice in the Commonwealth of Massachusetts. He regularly advises non-U. S. clients on structuring inbound pre-immigration tax strategies including basis step-up in legacy assets, avoiding the U. S. CFC and PFIC anti-deferral tax regimes, optimizing use of foreign tax credits, minimizing green card status as well as advising on and drafting of “drop-off trusts.”  Mr. Warshaw also advises long-term green card holders and U. S. citizens on planning to minimize their U. S. exit tax through gift programs, managing equity compensation and by drafting “expatriation” trusts and considerations of a change of domicile outside the U. S. He has also counseled clients in complying with their U. S. tax filing obligations by engaging accountants and bringing such taxpayers into compliance with their numerous U. S. international tax reporting requirements. Mr. Warshaw has also advised on the U. S. international tax aspects of cryptocurrency, including how to become U. S. tax compliant and how to mitigate U. S. tax implications prior to and following renouncing U. S. citizenship.

Mr. Lesperance is one of the world’s leading international tax and immigration advisors. He has successfully advised scores of high and ultra high net-worth individuals and their families, many of whom continue to seek his counsel today. In addition Mr. Lesperance has provided pro bono advice to many governments on how to improve their Citizenship by Investment, Residence by Investment or “Golden Visa” type programs to better meet the needs of his global clients. He is supported by a team of professionals, some of whom have worked with him since the early 1990s.

Mr. Master acts for some of the Firm's largest private clients and heads our Private Wealth Sector. He acts for high net worth individuals from across the world, but especially from the Middle East, where he acts for many ruling family members and billionaires – many of whose families have US links. Mr. Master's work for these families includes advising on the establishment of global assets holding structures, family governance projects and global real estate investments. He is a Visiting Professor at the University of Law, a Council Member of the International Academy of Estate and Trust Law, and an International Fellow of the American College of Trust and Estate Counsel. Mr. Master's lectures regularly in the UK and internationally on matters of private client interest. He has been featured in eprivateclient’s 50 Most Influential listing, the definitive listing of leading private wealth lawyers, in 2021, 2022 and 2023. Mr. Master's is admitted to practise in England and Wales.