Sandra Brown

Overview

I am a partner in the Private Wealth team in the Bristol office and am ranked in Band 1 for Private Wealth Law in independent legal guide Chambers High Net Worth. I am also recommended by the Legal 500.

I have over 30 years’ experience across a range of private client services, and is renowned in the legal directories and amongst my peers for my knowledge of wealth management and personal tax and trusts.

I specialise in advising clients on preserving their personal wealth and how best to provide for themselves and their families in the future.

I have a particular interest in the use of trusts in tax planning, including offshore trusts, and have a wealth of experience in matters that involve a foreign element, with many of my clients being domiciled outside the UK. I also act for a growing number of entrepreneurs and individuals with business interests.

I am a member of the Society of Trusts and Estates Practitoners.

I speak fluent Welsh and am passionate Wales rugby supporter.

Recent experience

Tax advice to a financier with income that significantly fluctuates. I advised a highly successful businessman in relation to the transfer of valuable assets into discretionary settlements free from inheritance tax. This was achieved by demonstrating that the sum transferred represented income and did not affect the donor’s normal standard of living. I persuaded HMRC that this was the case here. The client is a financier and his income fluctuates significantly each year, so the normal approach to this (making regular gifts from income of the same amount each year) could not be used. This alternative route required HMRC to be shown approximate income and expenditure levels over a period of time making clear that the income put into trust was surplus to normal requirements. Implementation of the advice meant that the client immediately removed £8 million from his taxable estate in the event of his death. For so long as surplus income is being generated, the intention is that the process will be repeated each year.

Advice to trustees and beneficiaries of an offshore trust. I advised the trustees and beneficiaries of an offshore trust in relation to the tax efficient distribution of assets to its UK based beneficiaries. The trust hold significant untaxed capital gains and unless action was taken there would be capital gains tax to pay on the death of the existing life tenant. The advice involved liaising with the trust’s accountants, analysing the existing tax exposures and assessing the long term objectives of the beneficiaries. Although the matter is still ongoing, if the recommended action is taken, then it may be possible to extract all of the capital from the trust without any charges to UK capital gains tax.

Estate planning advice to a Swedish national resident in the UK. Sandra gave estate planning advice to a Swedish national who is resident in the UK. The client owns properties of significant value in the UK, Sweden and France. Her position is made more complicated by the fact that her husband is resident for tax purposes in Ireland, but is a Swedish national. The advice given included a review of the family’s tax position following the introduction of the UK statutory residence test and succession planning advice in respect of a valuable property in London.

Estate planning advice to UK citizen residing in the UK. I advised a US citizen who is resident in the UK on her estate planning and testamentary wishes. The client possesses significant inherited wealth including agricultural interests and US trust interests. The client previously instructed a well known London based firm. Amongst other issues, the implementation of a new estate plan required a detailed understanding of the interaction between US Estate Duty and UK inheritance tax.