Events, Courses & Seminars

Opportunities for Isle of Man trust business in the US/UK marketplace

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Location: Upper Hall, Loch Promenade Church, Douglas.

This DQ sponsored seminar is with Patrick Harney. Patrick is an international private client lawyer with experience in private client tax and trust planning in the UK, Ireland and the US. He specialises in UK tax planning for non-domiciliaries and has particular experience in US-UK and UK-Irish tax planning. Patrick is recognised by his peers and the private wealth industry as a leading expert in this area of law.

Whereas the UK RND market for offshore trusts has faced pressures since 2008, there have been no equivalent pressures facing trusts driven by US tax considerations except perhaps the additional compliance burdens. This presentation is designed to demystify the world of US related trusts and equip the Isle of Man CSP with a knowledge of the basics sufficient to win US-connected trust business. Topics will include:

*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?

*What is a foreign grantor trust and why this can be a growth area for Isle of Man trust business?

*Retaining trust business in the Isle of Man after the death of the settlor of a foreign grantor trust through a PTC arrangement with a US CSP.

Coffee and registration will be from 12 noon for a prompt 12.30 pm start at the upper hall, Loch Promenade Church, Douglas. This seminar is free to staff of ACSP member firms and to associate members. This seminar is sponsored by DQ.

Patrick Harney has written and lectured extensively on US-UK tax and estate planning and is a regular speaker on cross-border US-UK tax matters at STEP events in the US. He advises high net worth individuals on tax efficient structuring of property transactions. Patrick also advises domestic UK families on wealth structuring and has a particular expertise in the use of family partnerships and family investment companies as a tax efficient wealth holding vehicle. Patrick qualified as a solicitor in Ireland in 1997 and in England and Wales in 2003. He spent two years on secondment to a leading private client law firm in New York before joining Forsters as a partner in 2007. Patrick is recommended in the Citywealth Leaders List 2014 and is recognised in the 2014 edition of Super Lawyers.