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?
Monday 2 March (1130 - 1245)
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 |