Client Success Stories

A second-generation family business owner approached us with a projected IHT liability of over £3.5M. The estate comprised a trading company, a portfolio of let properties, and significant liquid investments accumulated over decades. Business Property Relief was only partially available because investment activity had crept into the trading company over time, diluting the relief.

We conducted a full estate review and identified that the trading and investment activities within the company needed to be separated to restore full BPR eligibility. We then designed a phased plan: a corporate reorganisation to ring-fence the trading activities, a family investment company for the investment assets, and a lifetime gifting programme using a discretionary trust. Each step was sequenced to maximise reliefs and minimise HMRC challenge risk.

Over an 18-month implementation period, the client's projected IHT exposure was reduced by an estimated £2.4M. The family retained full control of the business throughout, and the planning was structured to remain robust under the April 2026 BPR and APR changes.

A US citizen was relocating to London for a senior role at a UK technology firm. His existing investment portfolio — built up over 15 years in the US — was heavily exposed to UK collective funds that would be classified as PFICs once he became UK resident. Left unaddressed, this would have triggered punitive US tax treatment and complex annual reporting. He also needed guidance on the FIG regime and split-year residence.

We worked alongside his US CPA in the months before his move. We reviewed his entire investment portfolio, identified the PFIC-exposed holdings, and coordinated a pre-arrival restructuring that liquidated the problematic funds before UK residence was established. We then advised on FIG regime eligibility, confirmed split-year treatment for his arrival year, and set up a compliant UK investment structure going forward.

The client arrived in the UK with a clean, PFIC-free investment structure and a clear four-year FIG regime plan. The pre-arrival restructuring avoided an estimated £180K per year in punitive US PFIC charges, and both his UK and US advisers had a coordinated framework for ongoing compliance.

A property developer with a portfolio of build-to-let properties faced an IHT bill of approximately £2.3M. The properties were held in a mix of personal names and an SPV, and the mix of trading (development) and investment (rental) activity meant BPR was almost entirely unavailable. The client wanted to pass the portfolio to his children without forced sales.

We restructured the property holdings to separate the development arm (qualifying for BPR as a trading business) from the rental portfolio (which would not qualify). We then advised on a combination of lifetime gifts into a discretionary trust for the rental properties and BPR-protected succession planning for the trading business. We also navigated the April 2026 BPR/APR £2.5M threshold rules to ensure the planning remained effective.

The restructuring unlocked approximately £1.6M in IHT savings. The client's children now hold the rental properties in trust, and the trading business passes with full BPR. The plan was specifically designed to work within the new 2026 IHT regime.

A family with one US-citizen spouse and one UK-citizen spouse were returning to London after 12 years in New York. Their affairs were complex: a US 401(k), an IRA, UK ISAs held from before they left, and a US brokerage account with mutual funds that would be PFICs in the UK. They were also unsure whether to elect into the FIG regime and how to handle the US-UK treaty pension provisions.

We coordinated with their US CPA to build a pre-return plan. We advised on which US investments to restructure before UK residence, how the treaty applied to their 401(k) and IRA, and whether FIG regime relief was beneficial given their income profile. We also reviewed their UK ISA holdings — which are tax-free in the UK but taxable for US purposes — and advised on a compliant investment strategy going forward.

The family returned to London with a fully coordinated UK-US tax structure. The pre-return restructuring and treaty-based planning generated an estimated £95K annual saving compared to proceeding without advice. Their US CPA and our team now work from a shared framework, ensuring both sides remain aligned year after year.

A retired couple with a £6M estate — primarily their London home and an investment portfolio — faced an IHT bill of approximately £2.4M. They had done no formal planning beyond simple wills. With the April 2026 IHT changes approaching, including the new residence nil-rate band taper and the BPR/APR cap, they needed a plan that would work under the new regime.

We designed a multi-layered plan: a lifetime gifting programme using the annual exemptions and the seven-year rule, a property downsizing strategy to release capital for gifting, and a discretionary trust structure for the remaining estate. We also coordinated an updated will structure with their solicitor to ensure the nil-rate bands were fully utilised.

The couple's projected IHT exposure was reduced by an estimated £1.9M. The gifting programme is underway, the trust is established, and the plan is specifically structured to remain effective under the April 2026 regime changes.

A US-citizen founder was relocating to London to open a UK office. He was planning to sell a portion of his company shares to fund the move, but had not considered that becoming UK resident before the sale would bring him within UK capital gains tax — potentially adding a significant UK CGT charge on top of his US obligations.

We were brought in three months before his planned move. We advised on the timing of the share sale to ensure it completed before UK residence was established under the Statutory Residence Test, and coordinated with his US advisers on the Foreign Tax Credit implications. We also reviewed his pre-existing investments for PFIC exposure and advised on the FIG regime for his arrival year.

By sequencing the share sale before UK residence, the client avoided an estimated £320K in UK capital gains tax. The US side was fully coordinated, and he arrived in London with a clear FIG regime plan and a PFIC-compliant investment structure.

A client purchasing a £1.8M property in central London with a self-contained commercial unit on the ground floor had been advised by their conveyancer that SDLT would be £93,750 at residential rates. The 3% additional dwelling surcharge also applied, making the total SDLT even higher.

We reviewed the transaction and identified that the commercial unit meant the property qualified for mixed-use classification. We prepared a robust analysis demonstrating the genuine non-residential element and advised the conveyancer on the correct SDLT return completion.

The transaction was classified as mixed-use, reducing SDLT from £153,750 (residential + surcharge) to £64,950 (non-residential rates). The client saved £88,800 in total, and the classification was accepted by HMRC without challenge.

A client who had purchased a property with a self-contained annexe in early 2024 — before Multiple Dwellings Relief was abolished from 1 June 2024 — contacted us after reading about MDR on our SDLT guide. Their conveyancer had not identified MDR at the time of purchase, and the client had paid £63,750 in SDLT on the £1.2M purchase.

We assessed the property and confirmed that the annexe qualified as a separate dwelling with its own living area, kitchen, and bathroom. We prepared a retrospective MDR claim, amending the original SDLT return within the 12-month amendment window. We also assessed whether mixed-use treatment could apply for even greater savings.

HMRC accepted the MDR claim, reducing the SDLT from £63,750 to £28,750 — a refund of £35,000 plus interest. Note: MDR was abolished for purchases completing on or after 1 June 2024, so this relief is no longer available for new transactions — but retrospective claims for qualifying pre-abolition purchases remain possible within the amendment window.

A fast-growing tech startup wanted to grant share options to 12 key employees but had been advised that unapproved options would trigger income tax at 45% on exercise, plus employer NIC. The company qualified for EMI but had no scheme in place, and the founders were unsure about valuation and compliance.

We assessed the company's EMI eligibility, obtained an HMRC Advance Assurance on the share valuation, drafted the EMI plan rules with their solicitor, and managed the grant process — including the critical 92-day notifications for all 12 employees.

The EMI scheme was fully compliant and operational within 6 weeks. When employees exercise and sell their shares, they'll pay 18% CGT (BADR) instead of up to 45% income tax — saving an estimated £280,000 across the team. The company also benefits from a corporation tax deduction on exercise.

A company preparing for a Series A round wanted to incentivise senior hires with equity, but the founders didn't want to dilute their own shareholdings through an EMI scheme. They also wanted employees to benefit only from future growth, not existing value.

We designed a growth share structure with a hurdle equal to the current company valuation. New growth shares were issued to senior employees at a low market value, meaning they only participate in value created above the hurdle. We obtained HMRC valuation agreement and structured the articles of association to accommodate the new share class.

The growth shares were issued compliantly, and employees will pay 18% CGT (BADR) on their gains — rather than up to 45% income tax. The founders retained full ownership of existing value, and the structure was attractive to incoming Series A investors.

A senior European executive was relocating to London from Switzerland. He had substantial foreign investment income and wanted to understand whether the new FIG regime (replacing the non-dom remittance basis) would provide relief, and how to structure his investments to maximise the benefit during the 4-year period.

We assessed his eligibility for the FIG regime — confirming he hadn't been UK resident in the previous 10 years. We then advised on restructuring his Swiss investments to ensure the income and gains qualified for FIG relief, and coordinated with his Swiss tax adviser on the cross-border position.

The client's foreign investment income and gains are fully relieved from UK tax for his first 4 years of UK residence — an estimated £240,000 in tax relief over the period. We've also built a plan for the end of the FIG period to minimise the transition to full UK taxation.

A group with two distinct trading divisions — one in manufacturing and one in property development — wanted to separate the businesses so the founding shareholders could sell the manufacturing arm while retaining the property business. Without restructuring, a sale would trigger a full CGT charge at 24%.

We designed a statutory demerger under CTA 2010 Section 1075, distributing the manufacturing subsidiary's shares to the shareholders tax-free. We obtained HMRC clearance in advance, confirming the commercial rationale and the tax treatment. We coordinated with the company's solicitors on the legal implementation.

The demerger completed without triggering any immediate tax charge. The shareholders subsequently sold the manufacturing business, qualifying for BADR (currently 18% CGT from April 2026) rather than the standard 24% CGT rate. The total saving was £3.2M in CGT compared to a direct sale without restructuring.

A business owner received a COP9 letter from HMRC alleging serious tax fraud spanning 5 years. The client was facing potential criminal prosecution, and their existing accountant had no experience with COP9 cases. The client was understandably terrified.

We immediately advised accepting the Contractual Disclosure Facility (CDF) and engaged a lawyer to ensure legal privilege on strategic communications. We conducted a thorough review of 5 years of records to identify all irregularities — ensuring a full and complete disclosure — and prepared the outline and detailed disclosures for HMRC.

HMRC accepted the full disclosure and the case was resolved through a civil settlement. The client paid the tax due plus interest and a 20% penalty (reduced for full disclosure), but avoided criminal prosecution entirely. The matter was closed within 14 months — significantly faster than a typical COP9 investigation.

An owner-managed business was preparing for a trade sale, but the group structure included dormant subsidiaries and mixed trading and investment assets. The buyer wanted a clean structure, and the existing group would have triggered a substantial corporation tax charge on pre-completion restructuring.

We designed a multi-step simplification plan: removing dormant companies, consolidating trading activities, and separating investment assets. We obtained HMRC clearance under Section 138 for each step and coordinated with the buyer's advisers to ensure the restructuring didn't delay the transaction timetable.

The group was simplified and ready for sale within 4 months. The restructuring saved £950,000 in corporation tax that would otherwise have been triggered, and the clean structure contributed to a smoother sale process and a higher sale price.

A property company had purchased a commercial building with a residential flat above for £2.4M. Their conveyancer had classified it as residential, applying residential SDLT rates — resulting in SDLT of £186,000. The client believed the transaction should have been classified as mixed-use.

We reviewed the transaction and confirmed that the residential flat was ancillary to the commercial use, and the property qualified for mixed-use (non-residential) SDLT rates. We amended the SDLT return within the 12-month window and prepared a detailed justification for HMRC.

HMRC accepted the reclassification, reducing SDLT from £186,000 to £114,000 — a refund of £72,000 plus interest. The client used a portion of the refund to invest in further SDLT planning advice for subsequent property acquisitions.