One minute with Sara Morgan, Director at Fieldfisher.
What’s keeping you busy at work?
My client base includes many non-domiciled UK residents (as well as their advisers and trustees) who have been impacted by the recent proposals. Keeping track of the announcements and advising clients on the potential implications and options for them is taking up a good deal of my time at the moment.
What would you say is unique to your area of tax work?
The private client world brings a never-ending variety of interesting and intellectually enjoyable work. Every family is different and brings its own complexities: the approach to the advice needed may be driven by the high profile nature of certain clients or their level of wealth; equally, there may be issues within the internal family relationships which require careful handling. There are always factors beyond the pure tax analysis to be understood and carefully built into our advice.
If you could make one change to tax, what would it be?
The change I would like to see is not for my clients but for the hard-working single parents out there. I would love to see the hidden single parent penalties in the tax and benefits legislation quietly spirited away. No fanfare required.
What do you know now that you wish you’d known at the start of your career?
I wish I had known that the intellectual challenges and problem-solving would never end and that that would be the root of the most satisfying part of the job – that is, the Eureka! moment when the solution becomes clear and you can see the right path through for your client’s situation.
A nugget of wisdom I like to share with people starting out on their tax career is that they will always be learning and adapting their skills and knowledge to new situations and structures: just when you think you have a comprehensive understanding of a tax provision, along comes a client with a set of circumstances which causes you to open up the legislation books again, look at the provisions and scratch your head as to how this particular circumstance fits.
My hope is that the knowledge that I am still learning after almost 20 years, liberates those starting out from feeling that they should be aiming to ‘know everything’ and encourages them to just keep reading, thinking and analysing.
Are there any new rules that are causing a particular problem in practice?
Many of my clients rely on the tax regime for non-domiciled residents, so the proposals announced by the Conservative government in March (and the follow-up announcements from the Labour Party) have been a major source of concern for them. The current position of limbo creates many difficulties as an adviser.
Until we see some draft legislation (hopefully in the Autumn, if not before), it is impossible to advise with any certainty of outcome. That uncertainty is causing clients to seek advice about leaving the UK – this being one of the few options where there is relative certainty about their tax treatment post-April 2025. As a result, advice for those clients at the moment is largely focusing on the application of the statutory residence test, considering their options for alternative destination jurisdictions and assessing whether there is scope to adjust asset holding structures to give a better chance of protection. We are also reviewing the position of existing clients to ensure that they are ready to make decisions as quickly as possible once we do have more clarity.
Once we have more certainty around the new rules, I expect the emphasis of advice to shift towards bespoke analysis of the impact of the changes on specific clients and their family asset holding structures (particularly trusts). If the future government does not delay the proposed timetable for the changes, it is going to be an extremely busy second half of the tax year.
You might not know this about me but...
I have three wonderful children so life is never dull! I am happiest when we step away from the day-to-day and enjoy each other’s company, whether camping with friends or simply watching a film together.
One minute with Sara Morgan, Director at Fieldfisher.
What’s keeping you busy at work?
My client base includes many non-domiciled UK residents (as well as their advisers and trustees) who have been impacted by the recent proposals. Keeping track of the announcements and advising clients on the potential implications and options for them is taking up a good deal of my time at the moment.
What would you say is unique to your area of tax work?
The private client world brings a never-ending variety of interesting and intellectually enjoyable work. Every family is different and brings its own complexities: the approach to the advice needed may be driven by the high profile nature of certain clients or their level of wealth; equally, there may be issues within the internal family relationships which require careful handling. There are always factors beyond the pure tax analysis to be understood and carefully built into our advice.
If you could make one change to tax, what would it be?
The change I would like to see is not for my clients but for the hard-working single parents out there. I would love to see the hidden single parent penalties in the tax and benefits legislation quietly spirited away. No fanfare required.
What do you know now that you wish you’d known at the start of your career?
I wish I had known that the intellectual challenges and problem-solving would never end and that that would be the root of the most satisfying part of the job – that is, the Eureka! moment when the solution becomes clear and you can see the right path through for your client’s situation.
A nugget of wisdom I like to share with people starting out on their tax career is that they will always be learning and adapting their skills and knowledge to new situations and structures: just when you think you have a comprehensive understanding of a tax provision, along comes a client with a set of circumstances which causes you to open up the legislation books again, look at the provisions and scratch your head as to how this particular circumstance fits.
My hope is that the knowledge that I am still learning after almost 20 years, liberates those starting out from feeling that they should be aiming to ‘know everything’ and encourages them to just keep reading, thinking and analysing.
Are there any new rules that are causing a particular problem in practice?
Many of my clients rely on the tax regime for non-domiciled residents, so the proposals announced by the Conservative government in March (and the follow-up announcements from the Labour Party) have been a major source of concern for them. The current position of limbo creates many difficulties as an adviser.
Until we see some draft legislation (hopefully in the Autumn, if not before), it is impossible to advise with any certainty of outcome. That uncertainty is causing clients to seek advice about leaving the UK – this being one of the few options where there is relative certainty about their tax treatment post-April 2025. As a result, advice for those clients at the moment is largely focusing on the application of the statutory residence test, considering their options for alternative destination jurisdictions and assessing whether there is scope to adjust asset holding structures to give a better chance of protection. We are also reviewing the position of existing clients to ensure that they are ready to make decisions as quickly as possible once we do have more clarity.
Once we have more certainty around the new rules, I expect the emphasis of advice to shift towards bespoke analysis of the impact of the changes on specific clients and their family asset holding structures (particularly trusts). If the future government does not delay the proposed timetable for the changes, it is going to be an extremely busy second half of the tax year.
You might not know this about me but...
I have three wonderful children so life is never dull! I am happiest when we step away from the day-to-day and enjoy each other’s company, whether camping with friends or simply watching a film together.
