What you need to know pre-April 2017

The recent summer budget saw the announcement that significant changes will be made to the regime for non-domiciled individuals from April 2017 onward. We also saw that further changes will be introduced to the taxation of structures holding UK residential property.

The ramifications for both clients and their advisers cannot be underestimated. The window for clients to seek advice and potentially restructure their affairs in advance of the changes is limited but, the opportunity does exist.

Edwin Coe’s experienced tax team will be discussing the impending changes, what it means for clients, and what opportunities still exist. They will also be available to address any specific concerns or issues you might have.


  • The 15 year rule change
  • Excluded property trust structures
  • Use of life assurance
  • Temporary non-residence planning
  • Revisions to the residential property regime
  • Double Taxation Agreements
  • The widening of the scope of Inheritance Tax.


Frank Stachan

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

Tax Services Partner

Sean Bannister

Sean is a Partner within the Tax Services team, which forms part of Edwin Coe’s Private Client team. Sean acts for high-net-worth and ultra-high-net-worth individuals, entrepreneurs, companies and trustees. He specialises on 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 client's the right advice at the right time.

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