Tom O’Reilly | Fieldfisher
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My practice covers advising both private and corporate clients on their interactions with HMRC, including owner-managed businesses, large corporates, trustees, high-net-worth individuals, and multi-generational families. I have extensive experience in obtaining favourable settlements for clients with high value, complex and worldwide tax affairs under enquiry with HMRC. The vast majority of my clients obtain settlements with HMRC without the time and publicity involved in court proceedings.
 
Where a favourable settlement is not possible, I litigate clients’ disputes through the Tax Tribunals and UK courts.
 
I have experience advising clients and engaging with HMRC in a wide range of situations, including tax enquiries, discovery assessments and determinations, Code of Practice 9 enquiries, voluntary disclosures and Alternative Dispute Resolution proceedings. I also advise clients on proactively minimising the risk of HMRC enquiries including the use of clearance procedures and “white space” disclosures.
 
I represent clients with tax issues across all direct taxes, including income tax, capital gains tax, corporation tax, and inheritance tax, as well as indirect taxes.
 
I also advise high and ultra-high net worth individuals, as well as their trustees and family offices, on structuring and tax planning arrangements, including succession planning and on the use of trusts. Many of my clients are non-resident and/or non-domiciled and I have significant practical experience in this area.

Areas of Expertise

Tax and Structuring

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