Overview Income Arising Overseas Estate Planning Divesting Of Personal Assets Inheritance Tax Planning Pre Migration Planning

Income Arising Overseas

Nancy Johnson, a Canadian individual, has acquired some luxury apartments in France along the coast of the Mediterranean. It is her intention that the apartments will be rented out to third parties. In case of the sale of the apartments or when Nancy dies, capital gains taxes and inheritance taxes should be avoided or reduced as much as possible.

In addition, Nancy wonders how high taxes on rental income and/or taxes on capital gains in case of sale of the apartments can be avoided or reduced as much as possible.

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Estate Planning

Bernard Shaw, a widower of 65, is planning to remarry with a Canadian woman and emigrate to Canada. At present, Mr. Shaw is resident in the UK. He has two children; a son living in the Bahamas, and a daughter who married a German man and has been a resident of Germany for more than 10 years. His new wife also has two children from her first marriage, one son who lives in Brazil and a daughter living in the United States.

Before he remarries, Mr. Shaw wishes to come to a comprehensive, tax effective arrangement for the administration and the transfer of his property, if any, and the benefits derived there from after his death.

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Divesting Of Personal Assets

Olga Barschett receives substantial amounts of royalties (and dividends) from the Russian company she works for, which she is subject to tax in the Russian Federation. She wonders whether she can exploit the patents in a more tax-effective way by bringing the patents offshore. At the same time, she intends to use the proceeds for both charitable purposes and the education of her grandchildren (at this moment, Olga has only one daughter of 12 years old).

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Inheritance Tax Planning

Pierre Dubois, a French citizen and resident, owns valuable works of art situated in several galleries and museums in the UK. The value of these works of art would certainly exceed the inheritance tax threshold for UK inheritance tax purposes, if Pierre would die in the very near future.

Mr. Dubois wonders how he can avoid exposure to UK inheritance tax.

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Pre Migration Planning

Mr. Abdullah, an executive working for a big oil company in Kuwait and also resident in Kuwait (0% income tax) is sent by his employer to Germany to become the CEO European operations of his company. It is expected that he will stay in Germany for a long period of time (at least 8 - 10 years) and he will take his family with him to Germany.

Mr. Abdullah is concerned about the high personal income tax rates in Germany (up to 48.5%). He wonders whether his exposure to German tax can be mitigated as a result of pre-migration tax planning.P>

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