John Goodchild

Expertise

  • International tax planning: advice on residence and domicile, the UK tax treatment of foreign residents and domiciliaries, double tax treaties and the uses and tax treatment of non-resident trusts and companies
  • UK tax planning: advice on inheritance tax, capital gains tax and other taxes relevant to UK individuals and trustees
  • Wills: advice leading to, and preparation of, English wills for UK and non-UK domiciled clients
  • International succession planning: advice on succession planning for clients domiciled outside the UK and for UK and foreign clients in relation to assets located in foreign jurisdictions
  • Probate: administration of UK and international estates and advice to executors
  • Trusts: advice to trustees and to beneficiaries on their rights, powers and duties
  • Agricultural property: advice in connection with agricultural property ownership and inheritance tax
  • Business assets: advice in connection with the ownership and taxation of businesses or assets used in businesses
  • Family business: tax and succession advice to families and trustees owning family businesses
  • Powers of attorney and Court of Protection: preparation and registration of powers of attorney, advice to attorneys, and advice on applications to the Court of Protection for deputyship, statutory wills and gifts
  • Charities: advice to charities and their trustees, on governance, incorporation

Experience

  • Acted as a trustee and guided the other trustees of two trusts holding shares in large private retail companies through a family conflict and resolved that conflict by piloting through a buy-in of own shares by one of the companies.  This also involved an application to the Court for judicial approval of the trustees’ proposal.  Assisted the family by formulating a strategy in relation to the two companies which, after a period of investment in both businesses, led to the extremely successful sale of one company.  Advised the trustees on pre-sale planning to mitigate capital gains tax
  • Advised a billionaire foreign client on UK tax planning.  This consisted of advice on tax residence, the remittance basis of taxation applicable to foreign domiciled individuals, the impact of the double tax treaty between the UK and the individual’s “home” country, the use of trusts in relation to UK assets and assets located outside the UK and all relevant anti-avoidance legislation.  As part of the overall brief advice was given on structuring to hold extremely valuable real estate purchased in England
  • Advised a US citizen on succession and tax planning in relation to in relation to UK and US assets, working with US lawyers to implement an arrangement to mitigate US Estate Tax involving a US limited liability partnership between the client and family members and subsequently overhauling the structure
  • Advised a married couple domiciled in an Islamic country on wills and succession planning in relation to their assets in England, USA, France and the Islamic country
  • Advised shareholders in a private company on capital gains tax planning in relation to their sale of the company which resulted in a re-organisation which enabled two shareholders, who would not have otherwise qualified for entrepreneur’s relief, to obtain that relief on their share disposals
  • Advised executors of an estate which contained copyrights and other valuable intellectual property rights both generally and in relation to a US breach of copyright claim brought against them.  This involved taking steps to prevent the US litigation from effectively freezing the estate and an application to the court in England for judicial approval of those arrangements
  • Advised a beneficiary of numerous trusts, which held land or private company shares relevant to a rural landed estate, on his position as a beneficiary and in relation to the duties of the trustees and the directors of the companies.  This led to successful, multiple, proceedings in the Chancery Division of the High Court against the trustees seeking their removal and damages for breach of trust
  • Acted as an executor and advised a co-executor in relation to connected estates of a husband and wife which involved three property investment companies, problematic issues in relation to the tax treatment and past tax affairs of those companies and difficult issues in relation to the beneficiaries of the estates
  • Advised a foreign domiciled client who was about to become UK tax resident on the tax and commercial implications of purchasing an offshore company which owned an intended residence in London as opposed to the underlying property itself
  • Advised an ultra high net worth client on his will and tax and estate planning.  The client wanted a substantial portion of his wealth to be used to create a private charitable foundation on his death and the work involved creating that foundation
  • Advised the trustees of a very valuable London estate on a complicated re-organisation of their assets designed to achieve a re-basing for capital gains tax purposes and opportunities to mitigate inheritance tax.

Career History

  • Qualified: 1985
  • 1991 – 2003: Gordon Dadds
  • 2004 – to date: Pemberton Greenish

Professional Memberships:

  • International Tax Planning Association
  • Society of Trust and Estate Practitioners
  • Charity Law Association
Share