31st Annual International Private Client Tax Conference

1 Mar - 3 Mar 2026

Session information

Mind the gap I: navigating civil law constructs in common law jurisdictions. Why make it easy when complexity is an option?

Description

In this panel, we will explore the challenges and potential pitfalls which arise when implementing civil law structures - such as Usufruct, Bewind and Fideicomiso - in common law jurisdictions. Panellists will unpack tax treatment, legal characterisation and ownership issues (during lifetime and after death), pinpointing where multi-jurisdictional mismatches may arise and how to anticipate and manage them. Through case studies, we will also cover reporting and transparency, as well as practical considerations for private client advisers trying to find pragmatic and predictable solutions which work across borders.

Session / Workshop Chair(s)

Iskra Doukova Macfarlanes, London, England
Dirk-Jan Maasland Loyens & Loeff, Amsterdam, Netherlands

Speakers

Michaël Khayat Arkwood SCP, Paris, France
Shawntel Randi Nixon Peabody, Boston, Massachusetts, USA; Committee Liaison Officer, Private Client Tax Committee
Nicola Saccardo Charles Russell Speechlys , London, England
Rahul Sharma Fasken, Toronto, Ontario, Canada