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Trusts Advisory Group Seminar February 2023


23 February 2023

8.00 to 9.45 (GMT)

44 Esplanade, Jersey

Trusts Advisory Group

The next Trusts Advisory Group Seminar, hosted by the Ogier team will take place on Thursday 23 February and will last approximately 1 hour and 15 minutes.

Patrick Harney and Filippo Noseda will be joining us from Mishcon de Reya. Patrick is a Partner in Mishcon Private. A market leading international private client lawyer who has worked in Dublin, London and New York, Patrick specialises in cross border tax advice with a particular focus on US-UK and UK-Irish tax, trust and estate planning and UK resident non-domiciled tax planning.

Filippo is a Partner in Mishcon Private and a Visiting Professor at King’s College, London, where he teaches International and Comparative Trust Law. A dual qualified English solicitor and Swiss lawyer (Rechtsanwalt) he advises clients on international tax and estate planning issues.  More recently, he appeared as an expert before the Council of Europe and the EU data protection authorities in connection with the introduction of the OECD's Common Reporting Standard (CRS) and the EU's Beneficial Ownership Registers. 

Filippo played a pivotal role in the recent and seminal ECJ decision that granting public access to the identity and personal data of beneficial owners would infringe the right to respect for private and family life, and the right to the protection of personal data enshrined respectively in Articles 7 and 8 of the Charter of Fundamental Rights of the European Union. 

In this seminar, Patrick and Filippo will be discussing the opportunities for Jersey trust business in the US/UK marketplace.  They will cover the following points:

  • Fundamentals of US taxation affecting trusts and individuals

  • Differences between US and UK trusts and their taxation

  • What are the "throwback rules" and why are foreign trusts so bad from a US perspective?

  • Foreign grantor trusts and why this can be a growth area for Jersey trust business?

  • Retaining trust business in Jersey after the death of the settlor of a foreign grantor trust through a PTC arrangement with a US CSP

Matthew Shaxson, Group Partner at Ogier will be presenting on:

  • AML/CFT Scope Exemptions: Implications for private wealth structures.

A light breakfast will be served prior to the seminar which will also be an opportunity to network.

Please email Alessia Zammataro if you would like to attend the seminar.

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