Following the recently announced changes to the taxation of long term UK tax resident non-domiciled individuals (RNDs), Edwin Coe’s Tax Services team will be hosting a seminar focusing on excluded property trust (EPT) structuring. It is widely expected that EPTs will be a vital tool for RNDs in managing their exposure to UK taxes following the changes due to take effect from April 2017 onward.

The seminar will focus on the following issues:

  1. Post April 2017 – the changing landscape for RNDs
  2. What now – how do you structure non-UK assets in advance of the changes?
  3. To loan or not to loan?
  4. Transfer of Assets Abroad (TAA) – changing the taxation of non-UK trusts
  5. Existing EPTs
  6. The confusing issue of residential property – uncertainty around existing EPTs holding UK situated residential property via an SPV.

The event is targeted at those who advise RND clients in relation to either their tax affairs or wealth.


Frank Strachan

Head of Tax Services

Frank joined Edwin Coe as a partner in 2012. He leads the Tax Services team which specialises in advising clients who are subjected to challenges by the tax authorities, as well as advising high-net-worth clients and families wishing to ensure that their tax affairs are suitable for their needs.

Frank has more than 20 years’ experience in tax dispute matters and is an experienced tax dispute resolution practitioner. His detailed knowledge of HMRC’s practices and procedures means that he is able to achieve excellent settlement terms for clients.

Frank is recognised as one of the leading practitioners in this specialised field and works closely with other members of the Private Client Group to offer a comprehensive service to private clients.

Sean Bannister


Sean Bannister

Sean is a Partner within the Tax Services team and acts for high-net-worth and ultra-high-net-worth individuals, entrepreneurs, companies and trustees. He specialises in advising clients in relation to their personal tax affairs and resolving disputes with HMRC.

Sean provides private client advice to international clients and entrepreneurs with a particular focus on wealth structuring, issues around residence and domicile, UK investment for non-residents (with a particular focus on property driven projects), and offshore trust/company/foundation arrangements. In addition, Sean acts for wealth management firms, fiduciary businesses, and offshore trustees on issues of UK taxation.

Sean also has significant experience assisting clients facing a tax enquiry or addressing historic irregularities via HMRC disclosure facilities (ODF/NDO/LDF) and Sean is well placed to offer clients the right advice at the right time.

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