The Private Wealth & Private Client Review - Edition 5

John Riches
  • Editor:
  • John Riches
  • RMW Law LLP

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The first six months of 2016 have been characterised by turbulence for the world in general, and particularly for those holding significant private wealth. The key development of 2016 to date has been the publication of the ‘Panama Papers’. The response to the publication from governments and the Organisation for Economic Co-operation and Development (OECD) has reinforced trends seen in prior years towards greater transparency and regulation in the domain of cross-border holding structures and in the context of beneficial ownership information.

…it has never been more important for advisers to give balanced and considered advice to families on how best to structure their arrangements, not just in the light of prevailing family circumstances and tax considerations, but also in the knowledge of the likelihood that information about the holding structure will be subjected to greater regulatory, government and potentially public disclosure in the years ahead. The paradigm that currently prevails in Western Europe is markedly different from that applicable in Asia, the Middle East and Latin America.

It remains to be seen whether, in the long term, many international families who have compliant structures that are fully disclosed to tax authorities will favour the United States as a tax-favoured jurisdiction from which to administer their family structures. This is on the basis that with a thriving domestic trust industry, the US could well be seen as a reputable jurisdiction which protects families from unwarranted public intrusion into their personal affairs to a greater extent than traditional offshore finance centres if beneficial ownership registers do become public in due course.

About the Editor

John works with family offices on a cross-border basis and deals with structuring for UK residents and resident non-domiciled families. He creates structures for active entrepreneurs to hold business interests. He is recognised as a leading authority in the area of family governance and has written and spoken extensively on this topic.

John founded RMW Law LLP in July 2011 with Samantha Morgan. RMW Law LLP is a niche legal practice dedicated to working for a limited range of international families and family offices. John remains a consultant at international law firm Withers LLP, where he was a partner from 1996 to 2011.

 John has had a variety of senior posts within the Society of Trust and Estate Practitioners over many years. As co-chair of the public policy committee, John has been responsible for liaising with national and supranational bodies on matters of tax policy affecting wealthy families, and has been consulted by the Organisation for Economic Co-operation and Development in respect of its initiative for high net worth individuals; he has also attended a number of sessions of the Financial Action Task Force (FATF) Private Sector Consultative Forum, where FATF seeks views from the private sector on its proposals and guidance to member states. He has been working extensively over the last 12 months with OECD in representing the views of the private wealth sector on the introduction of the Common Reporting Standard.


The publisher acknowledges and thanks the following for their learned assistance throughout the preparation of this book:

Editors' Preface

  • John Riches
  • RMW Law LLP

EU Developments

  • Richard Frimston
  • Russell Cooke-Solicitors

The Foreign Account Tax Compliance Act

  • Henry Christensen III and Toni Ann Kruse
  • McDermott Will & Emery

Notes On The Taxiation Of Works Of Art In The United Kingdom

  • Ruth Cornett
  • Christie's

OECD Developments

  • George Hodgson
  • STEP

Moden Trust Design

  • Todd D Mayo
  • Perspecta Trust


  • Niklas JRM Schmidt and Karl Binder
  • Wolf Theiss


  • John F Wilson
  • McKinney, Bancroft & Hughes


  • Ferenc Ballegeer
  • FB Private Wealth Law


  • Alec R Anderson
  • Conyers Dill & Pearman Limited


  • Humberto de Haro Sanches
  • Ulhôa Canto, Rezende e Guerra - Advogados


  • Margaret R O’Sullivan, Jenny K Hughes and Christopher Kostoff
  • O'Sullivan Estate Lawyers

Cayman Islands

  • Alan Milgate
  • Rawlinson & Hunter


  • Elias Neocleous and Philippos Aristotelous
  • Andreas Neocleous & Co LLC


  • Ossi Haapaniemi, Lauri Lehmusoja and Stefan Stellato
  • Hannes Snellman Attorneys Ltd


  • Line-Alexa Glotin
  • UGGC


  • Andreas Richter and Anna Katharina Gollan
  • P+P Pöllath + Partners


  • Peter Montegriffo QC
  • Hassans - International Law Firm


  • Aspasia Malliou and Maria Kilatou
  • Potamitis Verkris


  • Mr Keith Corbin
  • Nerine Trust Company Limited

Hong Kong

  • Ian Devereux and Silvia On
  • Stephenson Harwood


  • Janos Pasztor
  • Wolf Theiss


  • Nicola Saccardo
  • Maisto e Associati


  • Markus Summer and Hasan Inetas
  • Marxer & Partner


  • Simone Retter
  • Retter Avocats


  • DP Naban, SM Shanmugam, Josiah Lim Yun-Xi, Heng Jia, Ngo Su Ning and Cindy Bong Xin Yi
  • Lee Hishammuddin Allen & Gledhill


  • Jean-Philippe Chetcuti and Priscilla Mifsud Parker
  • Chetcuti Cauchi Advocates


  • Alfredo Sánchez Torrado and Roberto Padilla Ordaz
  • Chevez Ruiz Zamarripa


  • Dirk-Jan Maasland, Frank Deurvorst and Jules de Beer
  • Bluelyn

New Zealand

  • Geoffrey Cone and Claudia Shan
  • Cone Marshall Limited


  • Sławomir Łuczak and Karolina Gotfryd
  • SoŁtysiński Kawecki & Szlęzak


  • José Pedroso de Melo
  • SRS Advogados


  • Maxim Alekseyev, Kira Egorova, Elena Novikova and Ekaterina Vasina
  • ALRUD Law Firm


  • Chua Yee Hoong
  • KhattarWong LLP, a member of Withers KhattarWong


  • Pablo Alarcón
  • Alarcón Espinosa Abogados


  • Mark Barmes, Frédéric Neukomm and Heini Rüdisühli
  • Lenz & Staehelin

United Arab Emirates

  • Amjad Ali Khan, Stuart Walker and Abdus Samad
  • Afridi & Angell


  • Alina Plyushch and Dmytro Riabikin
  • Sayenko Kharenko

United Kingdom

  • Christopher Groves
  • Withers LLP


  • Basil Zirinis, Katherine DeMamiel, Elizabeth Kubanik and Susan Song
  • Sullivan & Cromwell LLP

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