Taxation

Members of Three Stone handle a wide range of private client taxation matters, providing both advice and advocacy.

Advisory work

Three Stone’s specialist Private Client Tax Advisory practice provides clear and practical advice to solicitors, accountants and foreign lawyers on all UK tax issues affecting individuals, and their businesses, estates, and trusts. Areas of expertise include advice on:

• Inheritance Tax;
• Capital Gains Tax;
• Stamp Duty Land Tax;
• Income Tax;
• Residence, domicile and the remittance basis of taxation;
• The taxation of onshore and offshore Trusts;
• The taxation of Wills and Estates, including cross-border Estates;
• The taxation of privately-owned UK businesses, including Farms and Landed Estates; and
• The tax efficient structuring of international privately-owned businesses with a UK link.

As well as providing written advice (Tax Opinions), and advice in conference, our members are adept in drafting the key documentation required to implement the proposed tax planning.  While the subject matter of advice given is often complex, the guiding principle is that what clients need is clear practical advice as to their options.

Advocacy and disputes

Three Stone’s specialist Private Client Tax Advocacy practice assists taxpayers when their disputes with HMRC have reached the litigious stage.  Our members have experience in taking cases to the First Tier Tax Tribunal and beyond on appeal.

Given the private nature of private wealth, many wealthy individuals and families do not wish to engage in public litigation with HMRC.  Members specialise in providing written advocacy for private clients in disputes with HMRC before litigation commences.  Taking specialist advice on the content of initial reporting and subsequent correspondence with HMRC can often lead to early and discreet settlement in the taxpayer’s favour; examples including the settlement of domicile disputes, and the mitigation/avoiding of penalties on reporting historic unpaid tax liabilities to HMRC.

Private client tax issues are often at the heart of litigation not involving HMRC.  Members specialise in providing advocacy and advisory support in the context of:

• Contentious probate and trust litigation, including claims under the Inheritance (Provision for Family and Dependants) Act 1975, particularly in relation to the tax efficient structuring of Settlement Agreements and Court Orders. Members also provide joint tax advice to both parties in dispute seeking to find the most tax efficient settlement;
• Matrimonial litigation. Specialist tax advice on both divorce and in the preparation of Pre and Post Nuptial Agreements can often be the key to unlocking agreement between the parties; and
• Professional negligence litigation regarding tax advice. The UK tax code is highly complex and the issues involved on both making and defending negligence claims, but also on how the tax position of those affected might be mitigated, can benefit from specialist advice.