Tobias advises international families, trustees, and family offices on a wide range of cross-border private client matters.
His practice includes tax and succession planning, advising on UK tax treatment of offshore trusts and companies involving UK-resident beneficiaries or participators, and as well as quasi-trust structures including usufructs, foundations and US life estates.
Tobias has a specialism in advising US-connected clients on US/UK estate planning, wills, estate taxes, aligning US/UK tax credits and pre-residency planning. He has particular expertise in the UK treatment of US trusts, including revocable and irrevocable trusts, life insurance and PPLI structures, IHT-sheltered trusts, US LLCs and US retirement & tuition accounts.
Tobias also offers expert cross-border advice in probate and succession matters, notably those with US or EU connections (comprising of advice on the European Succession Regulation) and provides expert English law advice to assist foreign probate courts.
Recent work highlights
Advice on double tax exposure for US trusts with UK beneficiaries, including flipping US grantor/non-grantor tax treatment, pre-UK-residency planning, UK transfer-of-assets abroad code and motive defence, and sheltering US trust assets from UK inheritance tax.
Tax advice in rectifying a historic “trust mistake” matter including complex multi-million dollar structures in US, UK, Guernsey and Singapore, including advice on US LLC structures.
UK/US tax planning including US revocable living trusts (such as California, New York, Maine, Colorado, Michigan and North Carolina), IRA withdrawals and rollovers, US 529 Plans, and treaty claims.
Experience & education
2020 Joined Birketts LLP
2017 Qualified as solicitor
2015 – 2020 Hewitsons LLP
2012 – 2015 Paralegal at LGSS Law Ltd
2007 – 2010 Law M.A.(Hons) Christs College, University of Cambridge
Areas of Expertise
Accreditations
Society of Trust and Estate Practitioners (STEP)
Full member
Insights
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Americans arriving in the UK – have you made a new trust yet?legal updateAmericans arriving in the UK – have you made a new trust yet?
Multiple Authors23 Sep 2025 -
Non-Dom reforms – the opportunities and risks for US clientslegal updateNon-Dom reforms – the opportunities and risks for US clients
Multiple Authors18 Jun 2024
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Overseas holiday homes and the expected April 2025 IHT changeslegal updateOverseas holiday homes and the expected April 2025 IHT changes
Multiple Authors9 May 2024
