Navigating US/UK Cross-Border Tax Regulations

Rathbones

Thu 29 Oct 17:00

The IBSA have great pleasure inviting you to join Roy Saunders, Founder & Chairman of the IBSA Club, Mark Bibby of Rathbones, Emily Walton of S&W, John Kiely of Howard Kennedy, Conor Taylor of Alvarez & Marsal and Jeremy Glover of Jurit for a discussion group meeting exploring the tax, immigration, employment, and corporate structuring challenges faced by internationally mobile entrepreneurs and executives.

 

This session centres on a detailed case study: Zac, a US entrepreneur and founder of a successful technology business, relocates to London for three to five years to establish a European headquarters — accompanied by his COO, CTO, and CFO. Along the way, the group must navigate:

 

  • Immigration – choosing the right visa route, from skilled worker to Global Business Mobility routes
  • UK/US personal tax – managing dual tax residency, the new Foreign Income and Gains (FIG) regime, and the risk of double taxation
  • Corporate and international tax – permanent establishment risk, transfer pricing, GILTI, and PFIC exposure
  • Employment and equity – how existing US equity awards (ISOs, NSOs, RSUs) are treated under UK tax rules.

 

The case highlights just how easily these four areas collide and why coordinated, cross-border advice is essential from day one.  We'll bring together specialists in UK and US personal and corporate taxation, immigration, and wealth planning to unpack the issues and discuss practical strategies.  Since we will be receiving the Budget proposals the day before on October 28th, our panel will have the opportunity to discuss the changes proposed as they may affect Zac as well as UK entrepreneurs considering expatriation.

 

 

View the Case Study

 

 

This meeting will be hosted by Rathbones at their offices at 30 Gresham Street, London, EC2V 7QN on Thursday, 29th October at 17:00 (GMT).

 

Networking drinks will follow the discussion and offers the opportunity to meet fellow members and their guests. This event is free to IBSA members and invited guests.

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Speakers

Roy Saunders
Roy Saunders
Founder and Chairman, IBSA
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Roy Saunders

Founder and Chairman, IBSA

Since qualifying as a Chartered Accountant in 1967, Roy Saunders has accumulated a wealth of commercial experience working independently in commercial property, international tax, advertising and other industries. He is the Chairman of IFS, a boutique international tax practice based in central London. Academically, he is known throughout the world for his many books and publications, the foremost being his red book, International Tax Systems & Planning Techniques published by Sweet & Maxwell. Roy has also taught an MA Course on International Taxation at the Institute of Advanced Legal Studies at the University of London.

Roy is very proud of the fascinating client base of entrepreneurial individuals that he has built up at IFS. He feels strongly about the role that ethical tax structuring plays in the growth of an economy, and that this needs to be better understood by the public at large. Roy founded the IBSA to enable business professionals around the world to discover new business relationships and promote best practice by creating sustainable business structures compliant with international transparency, corporate governance and social responsibility.

Emily Walton
Emily Walton
Tax Partner, S&W
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Emily Walton

Tax Partner, S&W

Emily has over 15 years of experience specialising in US/UK cross-border tax advice and compliance, with a particular focus on US-connected clients holding non-US business interests.

Her notable client work includes pre-entry tax planning for individuals relocating between the US and UK, mitigating exposure across both jurisdictions through effective use of the Double Taxation Agreement. She advises US owner-managed businesses on structuring, tax elections, and associated US compliance obligations.

Emily has extensive experience supporting US individuals with interests in Controlled Foreign Corporations (CFCs), guiding clients through the Subpart F and Net CFC Tested Income (NCTI) regimes, as well as the Passive Foreign Investment Company (PFIC) rules. She has also led streamlined filings for US-connected individuals, collaborating closely with affected clients and legal counsel on complex matters, including issues arising under Section 965 and the Transition Tax affecting Controlled Foreign Corporations.

John Kiely
John Kiely
Partner & Head of Immigration, Howard Kennedy
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John Kiely

Partner & Head of Immigration, Howard Kennedy

As Head of Howard Kennedy’s Immigration team, John Kiely provides strategic and bespoke advice across all areas of UK immigration law.

John leads the firm’s corporate and private client immigration offering, with particular expertise in advising high-net-worth individuals, families and entrepreneurs on complex, high-value matters.

With over 13 years of experience, John is recognised for his expertise in complex immigration matters, including settlement and nationality issues, applications under Appendix FM, Tier 1 (Investor), Global Talent, Skilled Worker, Global Business Mobility, International Sportsperson and Innovator Founder routes. He also has significant experience in preparing discretionary applications outside the Immigration Rules based on Article 3 and Article 8 of the European Convention on Human Rights to safeguard clients’ rights in exceptional and sensitive circumstances.

John advises corporate clients on sponsor licence management and compliance obligations, helping businesses mitigate risk and avoid civil penalties.  He works closely with private wealth advisers, tax specialists and family offices to deliver integrated solutions for clients with significant assets and cross-border interests. John is regarded as an industry leader in Tech Nation visa applications and has developed niche expertise in International Sportsperson visas. His insights have been sought by national publications on football transfers and Government Body Endorsement criteria, and he has appeared in The Financial Times and The Economist in relation to immigration and high-net-worth matters.

John is ranked in Chambers and Partners High Net Worth Guide and Legal 500 for both corporate and private client immigration, reflecting his reputation for excellence in this specialist field.

Conor Taylor
Conor Taylor
US/UK Private Client Manager, Alvarez & Marsal
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Conor Taylor

US/UK Private Client Manager, Alvarez & Marsal

Conor works within a highly skilled and complex sector, offering practical and tailored advice, as well as assisting US and UK individuals to remain compliant with both their US and UK tax needs. 

Jeremy Glover
Jeremy Glover
Partner, Jurit
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Jeremy Glover

Partner, Jurit

Jeremy advises businesses on shareholder structures, board pay, management incentives, employee share plans, advisory employment law and advisory corporate law issues, as well as on investments. He has over 22 years' experience advising international businesses on legal and management issues, and is able to operate at a very high level, with significant experience advising at board level.

Jeremy has a successful track record leading and building teams of consultants, accountants and lawyers at Big 4 accounting firms and US and UK City law firms. He has substantial experience advising international businesses on executive compensation, employee incentives, M&A, IPOs, private equity, advisory corporate matters, corporate governance and employment. He has a proven ability to win and manage large client projects, with particular experience in international project management involving tax advisors across many jurisdictions.

Mark Bibby
Mark Bibby
Investment Manager, Rathbones
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Mark Bibby

Investment Manager, Rathbones

Mark is an Investment Manager in the Rathbones Private Office division.

Mark brings together investment management, financial planning, and wealth structuring, to ensure his clients' financial affairs are managed efficiently, their capital is invested effectively, and a comprehensive long-term plan is in place to achieve their financial goals.

Venue

Rathbones

30 Gresham Street
London 
EC2V 7QN

 

Rathbones is a leading provider of individual wealth management, asset management and related services to private clients, charities, trustees and professional partners.

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