Family Office Tax and Legal Structures David Kilshaw EY 24 May 2016

Some opening comments Family Office Tax and Legal Structures

There are estimated to be between 3,000 and 15,000 SFOs Half of them set up in the last 15 years Family Office Tax and Legal Structures

BUT “If you have seen one family office, you have seen one family office” - Dr Kirby Rouploch Family Office Tax and Legal Structures

AND “Like snowflakes, no two family offices are alike” Family Office Tax and Legal Structures

SO…… To talk about tax and legal structures in 10 minutes is quite a challenge! Family Office Tax and Legal Structures

The Solution A good guide Family Office Tax and Legal Structures

Qualities of a guide Purpose How? Where? Relationship Vision Family Office Tax and Legal Structures

Purpose I Investment Family Office Tax and Legal Structures

Purpose 2: The Family Glue Family Governance/Constitution Succession and Security Privacy Education Philanthropy Family Office Tax and Legal Structures

How? HOW!! Family Office Tax and Legal Structures

Seven steps towards a SFO Step One Assess current wealth and family situation Step Seven Monitoring and controlling Step Two Define goals Step Six Implementation Step Three Define function and scope of services Step Five Organise the family office Step Four Define legal and governance setup Family Office Tax and Legal Structures

Sample family legal structures Founder’s office Multigenerational family office Founder Accountant Personal Assistant External Advisors Lawyer Auditor Insurance Investments Family Office CEO or President Chief Operating Officer Chief Financial Officer Family Governing Board Business Board of Directors Chief Investment Officer Chief Philanthropic Officer Tax Accounting Bill Pay Partnership A/c Reporting Fiduciary Services TeClient Service Concierge Services Insurance Personal Security Communication Financial Planning Technology Real Estate Private Equity Marketable holdings Manager oversight Family Foundations Venture Philanthropy Impact Investing Investment Committee Foundation Board External Advisors Lawyer Auditor Consultant Insurance Security Investments Governance other … Closely Held Businesses Medium-sized family office Family Office CEO/President Family Council Business Board of Directors Foundations Tax, Accounting Bill Pay Partnership A/c Reporting Technology Fiduciary Services Financial Planning Real Estate Private Equity Marketable holdings Manager oversight Family Foundation Closely Held Businesses External Advisors Lawyer Auditor Consultant Insurance Investments Other Chief Financial Officer Chief Investment Officer Family Office Tax and Legal Structures

Where Family Office Tax and Legal Structures

Seven considerations when deciding where to set up the FO Homebase of (international) family members and patron NextGen more mobile Global tax compliance Cloud/new IT solutions enable international setup New locations such as Dubai, Qatar or Singapore Established locations revisited such as Liechtenstein, Luxemburg or Switzerland Where is the geographical center of the family? Safe environment (geopolitical risks) Legal stability Tax regime Discretion Availability of professionals for FO Presence of banks, advisors and lawyers Geographical connectivity 1 7 6 5 4 3 2 Family Office Tax and Legal Structures

Family offices and the fiscal authorities Family Office Tax and Legal Structures

Vision Family Office Tax and Legal Structures

Key visions Plan early Consult and lobby Review and double review Family Office Tax and Legal Structures

Conclusion Complex Costly Critical A good guide KISS Family Office Tax and Legal Structures

Professional Experience David Kilshaw Partner Private Client Services – London Direct Tel: +44 20 7783 0763 Mobile: +44 7710 578303 Email: dkilshaw@uk.ey.com Address: Ernst & Young LLP, 1 More London Place, London SE1 2AF Background David is a partner in EY’s private client team in London, where he heads their Family Office practice. Prior to joining EY in 2014, David was the head of another top four private client practice. David is also a qualified solicitor and was previously a partner in a leading City Law firm. David is listed in Spears Top Ten Private Client Accountants. In 2014 and 2015 Citi Wealth listed David as one of their “top 20 men in Private Wealth Management”. Professional Experience David has extensive experience of working with international clients on their tax affairs and the creation and management of their Family Offices. He acts for a number for major families who are based in London and elsewhere. David acts for several of the UK’s largest landed estates. He also advises banks and other wealth managers on the tax treatment of their products for non-doms. David advises on the UK tax aspects of property ownership structures and works with real estate colleagues to ensure they are relevant and commercially effective from the private client perspective. Skills David has over 30 years of experience of working with private clients, their investments and related structures. He works closely with colleagues in corporate finance, real estate and private equity. In 2012 he was named by Spears as one of their top 5 advisers in the UK and previous peer recognition includes Citiwealth’s accountant of the year in 2010. He won the Spear’s inaugural award for accountant of the year in 2007. In 2014 eprivateclient listed David as one of their top 50 private client advisers. In 2016 David was Who’s Who legal’s “Private Client Trust and Advisory Professional of the year”. Family Office Tax and Legal Structures