Suzanne Willis thinks of many of her clients as ‘being in the middle of the Atlantic’ – because of the way that business interests and family relationships tend to push and pull them from the UK to the US and back again. Willis has practised both UK and US tax since 1997 but tells Spear’s the past year has been a ‘surprising’ one, as she has had to help clients get to grips with a series of tax changes on both sides of the Atlantic. Brexit, however, is not a major concern for her clients: ‘They think if we stay or if we leave, there’s opportunity one way or the other.’ However, she does admit that the prospect of a socialist government and ‘the rates that are bandied around’ in terms of tax have begun to make some people nervous. The best thing to do now, she says, is ‘to think and plan flexibly’. Willis says that most clients she deals with ‘are more than willing to pay tax’ but are likely to baulk at the complexity and lack of clarity engendered by some of the new rules. In this respect, she sees an opportunity for other jurisdictions to court HNWs. ‘Italy and Portugal have introduced their own versions of the non-dom rules,’ she says. ‘They’re in Europe, the time zones are similar or exactly the same, and they’re nice places to live. Some of these jurisdictions are offering a simple and attractive tax regime for their economy – it’s been fantastic for the UK for 30 years or more, so why not?’
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