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Christopher Eames

Associate (Barrister)

About

Chris is an associate in the firm’s International Tax team with particular expertise in the UK tax issues that arise for non-resident individuals and US Persons.

He has extensive experience advising high-net-worth individuals and their structures, including offshore trusts and non-resident companies, on their UK tax obligations. His practice also includes advising on estate planning, especially for US Persons who are either living in the UK or who have UK assets.

Chris has a wide range of clients including crypto entrepreneurs, private equity executives, and start-up founders.

He has published articles in both the Society of Trust and Estate Practitioners (STEP) Journal and the Tax Journal including on algorithmic crypto trading and transferring carried interest into trust.

Experience

  • Advising a tech billionaire, with UK real estate worth c. £250m, on ceasing UK tax residence while still spending significant amounts of time in the UK.
  • Creating an offshore trust for the managing partner of a major private equity firm including transferring future entitlements to carried interest and advising on the UK tax consequences.
  • Pre-arrival planning for a US partner in a venture capital firm specialising in crypto investments including liquidating his current holding structure.
  • Opining on the UK tax analysis of US revocable trusts and other more complicated US estate planning structures.
  • Advising the beneficiary of a $1bn Liechtenstein trust on the tax treatment of converting the trust into a foreign grantor trust for US tax purposes.
  • Advising on, and implementing, the de-envelopment of UK real estate held in a trust and offshore company structure.

Credentials

  • Qualified as a Barrister: England & Wales (October 2020)