Brad F. Westerfield

Brad F.

Westerfield

Overview

Brad is an experienced US international tax, trusts and estates lawyer.  He has practiced in London since 2006 and primarily represents high net worth individuals and families who have connections to the United States.  His client base spans the United States, the United Kingdom, Continental Europe, the Middle East and Asia.  He is a frequent presenter and regularly works with non-US lawyers and other professionals on cross-border and multijurisdictional tax, trust and estate planning matters. His practice predominately focuses on international wealth transfer planning and structuring, tax controversy, compliance and penalty mitigation and tax related issues that stem from these areas.  Brad is “very responsive and explains complex technical issues clearly.” (Chambers 2022)

Experience

  • Advise high net worth families and their advisors with respect to US federal income, estate and gift tax issues, with a particular emphasis on integrated US/UK tax and estate planning from a US perspective.
  • Advise US and non-US individuals and businesses on structuring their investments from a US perspective.  
  • Advise on the establishment and taxation of US and foreign trusts from a US perspective. 
  • Advise individuals on the relinquishment of US citizenship or lawful permanent residency (green card) status.
  • Advise individuals, financial institutions and trust companies regarding US federal tax compliance, including FATCA and the IRS Voluntary Tax Disclosure programs.

Distinctions

  • Chambers HNW
    • Private Wealth Law (Foreign Experts) (London (Firms)), 2018-2024
  • Who's Who Legal
    • Private Client, 2020-2022

Bar Admissions

  • New York, 2007
  • Connecticut, 2007
  • Mississippi, 2006
  • U.S. Tax Court

Education

  • New York University, LL.M., Taxation, 2006
  • Mississippi College, J.D., cum laude, 2005
  • University of Mississippi, M.Tax., 2000
  • University of Mississippi, B.Accy., 1999

Associations

  • Society of Trust and Estate Practitioners
  • International Bar Association
    • Private Client Tax Committee
    • North American Regional Forum
  • American Bar Association
    • Section of Taxation
    • Section of Real Property, Trust and Estate Law
  • New York State Bar Association
    • Tax Section
    • Trusts and Estate Law Section
  • Mississippi Bar Association
    • Estate & Trusts Section

Papers, Presentations & Publications

  • Co-Presenter, "Insights into Tax Controversies and Investigations," TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2024.
  • Editor (US sections only), “Module 16, International Estate Planning” International Estate Planning Paper for the STEP/Irish Law Society Course, August 2024.
  • Co-Presenter, “Addressing Will and Estate Planning Difficulties and Strategies,” TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2023.
  • Co-Presenter, “Help! Get me in and out of here!”, TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2022.
  • Co-Presenter, “Divorce with a US Connected Person,” TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2022.
  • Editor (US sections only), “Module 15, International Estate Planning,” International Estate Planning Paper for the STEP/Irish Law Society Course, August 2022.  
  • Co-Presenter, “US Private Client Q&A,” Butler Snow Private Client Webinar, March 2022.
  • Co-Presenter, “US Tax, Trust and Estate Planning,” External Training Session Webinar, February 2022.
  • Presenter, “US Federal Tax Issues Related to Divorce,” External Training Session Webinar, May 2021.
  • Co-Presenter, “US Tax Briefing Webinar,” Butler Snow Private Client Webinar, April 2021.
  • Co-Presenter, “US Tax Briefing Webinar,” Butler Snow Private Client Webinar, October 2020.
  • Editor (US sections only), “Module 15, International Estate Planning,” International Estate Planning Paper for the STEP/Irish Law Society Course, September 2020.  
  • Co-Presenter, “US Tax Briefing,” Butler Snow Private Client Event, The Law Society, March 2020.
  • Co-Presenter, “US Private Client Briefing,” Butler Snow Private Client Event, The Law Society, London, February 2019.
  • Editor (US sections only), “Module 15, International Estate Planning,” International Estate Planning Paper for the STEP/Irish Law Society Course, July 2018.  
  • Co-Presenter, “Tax Cuts and Jobs Act: A Sea Change For International Families and Businesses,” External Training Session, London, February 2018.
  • Co-Presenter, “Tax Cuts and Jobs Act: A Sea Change For International Families and Businesses,” Butler Snow Private Client Event, The Law Society, February 2018.
  • Co-Presenter, “Trump and Taxes,” External Presentation, London, November 2017.
  • Co-Presenter, “US Taxation of Non-US (Foreign) Trusts,” External Training Session, London, August 2017.
  • Co-Presenter, “Classification of Trusts in the US,” Guernsey Annual STEP Conference, June 2017.
  • Presenter, “United States: Tax, Estate Planning & the EU Succession Regulation,” The Law Society Private Client Section Cross Border Conference, London, March 2016.
  • Presenter, “So Your Clients Want to Move Their Structures to the United States?”, STEP International Client SIG Conference, December 2015.
  • Presenter, “Planning for the Super Rich – US/UK Planning,” Offshore Investment Conference, London, July 2015.
  • Presenter, “Tackling the Complexities of the Interaction between US / UK Tax Regimes,” Transcontinental Trusts 2015, Geneva, Switzerland, June 2015. 
  • Presenter, “Estate & Tax Planning for the U.S. Citizen in the UK – Expatriation,” IBC Private Client Conference, London, May 2015.
  • Presenter, “The HNW Same Sex Family:  Going Global,” ABA Section of International Law, AIJA Conference, Brighton, April 2015.
  • Presenter, “US/UK Estate Planning and Procedure,” The Law Society Private Client Section Cross Border Conference, London, March 2015.
  • Quoted, "Wealthy Asians dash to ditch US Passports," Asian Investor, December 2014 
  • Co-Author, “ACA Finance Panel,” the American Magazine, December 2014.
  • Presenter, “Catching Up If You Are Out of Compliance,” American Citizens Abroad Town Hall Meeting, London, December 2014.
  • Presenter, “Efficient US/UK Estate and Trust Planning,” IBC Private Client Series Conference, London, November 2014.
  • Presenter, “US/UK Estate Planning and Joint Property Issues,” US Expatriate Tax Year-End Conference, London, October 2014.
  • Quoted, "3,000 Americans ditch their passports," CNN Money, 17 February 2014.
  • Presenter, "US Taxation of Non-US Trusts," US Expatriate Year-End Planning Conference, London, October 2013.
  • Co-Author, "Landmark US Supreme Court Decision May Extend US Tax Benefits to UK Civil Partners," Planning Notes International, Vol. 2013, June 28, 2013.
  • Presenter, "US Tax Issues in Divorce," London, March 2013.
  • Presenter, "US Tax Update and Introduction to Passive Foreign Investment Companies (PFICs)," London, February 2013.
  • Co-Author, "Crossing the Divide: US Tax-saving Opportunities for UK-based Americans," Northwest Resident Magazine, February 2013.
  • Co-Presenter, "US Citizens Abroad: Tax and Legislative Updates in an Ever-evolving World," London, October 2012.
  • Co-Author, "Transatlantic Thinking – Flexible Solutions for Those Facing a Planning Conundrum," April 2012.
  • Presenter, "US Taxation of Trusts (for UK Practitioners)," London, March 2012.
  • Co-Presenter, "US/UK Tax Issues for Americans Residing in the UK," London, 2012.
  • Co-Presenter, "Integrated US/UK Estate Planning," London, 2012 and 2011.
  • Co-Presenter, "The US HIRE Act – Catching Overseas Structures to Ensure Internal Compliance," STEP Conference Isle of Man, November 2010.
  • Co-Author, "Uncompensated Use of Trust Property Taxable to United States Persons," Briefing Note, May 2010.
  • Co-Author, "Death of the US Death Tax? Not all Roses for Families with UK Connections," The Offshore & International Taxation Review, Vol. 14, Iss. 3, 2010.

Brad F.

Westerfield

Overview

Brad is an experienced US international tax, trusts and estates lawyer.  He has practiced in London since 2006 and primarily represents high net worth individuals and families who have connections to the United States.  His client base spans the United States, the United Kingdom, Continental Europe, the Middle East and Asia.  He is a frequent presenter and regularly works with non-US lawyers and other professionals on cross-border and multijurisdictional tax, trust and estate planning matters. His practice predominately focuses on international wealth transfer planning and structuring, tax controversy, compliance and penalty mitigation and tax related issues that stem from these areas.  Brad is “very responsive and explains complex technical issues clearly.” (Chambers 2022)

Experience

  • Advise high net worth families and their advisors with respect to US federal income, estate and gift tax issues, with a particular emphasis on integrated US/UK tax and estate planning from a US perspective.
  • Advise US and non-US individuals and businesses on structuring their investments from a US perspective.  
  • Advise on the establishment and taxation of US and foreign trusts from a US perspective. 
  • Advise individuals on the relinquishment of US citizenship or lawful permanent residency (green card) status.
  • Advise individuals, financial institutions and trust companies regarding US federal tax compliance, including FATCA and the IRS Voluntary Tax Disclosure programs.

Distinctions

  • Chambers HNW
    • Private Wealth Law (Foreign Experts) (London (Firms)), 2018-2024
  • Who's Who Legal
    • Private Client, 2020-2022

Bar Admissions

  • New York, 2007
  • Connecticut, 2007
  • Mississippi, 2006
  • U.S. Tax Court

Education

  • New York University, LL.M., Taxation, 2006
  • Mississippi College, J.D., cum laude, 2005
  • University of Mississippi, M.Tax., 2000
  • University of Mississippi, B.Accy., 1999

Associations

  • Society of Trust and Estate Practitioners
  • International Bar Association
    • Private Client Tax Committee
    • North American Regional Forum
  • American Bar Association
    • Section of Taxation
    • Section of Real Property, Trust and Estate Law
  • New York State Bar Association
    • Tax Section
    • Trusts and Estate Law Section
  • Mississippi Bar Association
    • Estate & Trusts Section

Papers, Presentations & Publications

  • Co-Presenter, "Insights into Tax Controversies and Investigations," TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2024.
  • Editor (US sections only), “Module 16, International Estate Planning” International Estate Planning Paper for the STEP/Irish Law Society Course, August 2024.
  • Co-Presenter, “Addressing Will and Estate Planning Difficulties and Strategies,” TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2023.
  • Co-Presenter, “Help! Get me in and out of here!”, TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2022.
  • Co-Presenter, “Divorce with a US Connected Person,” TL4 TransAtlantic US/UK Tax and Estate Planning Conference, London, September 2022.
  • Editor (US sections only), “Module 15, International Estate Planning,” International Estate Planning Paper for the STEP/Irish Law Society Course, August 2022.  
  • Co-Presenter, “US Private Client Q&A,” Butler Snow Private Client Webinar, March 2022.
  • Co-Presenter, “US Tax, Trust and Estate Planning,” External Training Session Webinar, February 2022.
  • Presenter, “US Federal Tax Issues Related to Divorce,” External Training Session Webinar, May 2021.
  • Co-Presenter, “US Tax Briefing Webinar,” Butler Snow Private Client Webinar, April 2021.
  • Co-Presenter, “US Tax Briefing Webinar,” Butler Snow Private Client Webinar, October 2020.
  • Editor (US sections only), “Module 15, International Estate Planning,” International Estate Planning Paper for the STEP/Irish Law Society Course, September 2020.  
  • Co-Presenter, “US Tax Briefing,” Butler Snow Private Client Event, The Law Society, March 2020.
  • Co-Presenter, “US Private Client Briefing,” Butler Snow Private Client Event, The Law Society, London, February 2019.
  • Editor (US sections only), “Module 15, International Estate Planning,” International Estate Planning Paper for the STEP/Irish Law Society Course, July 2018.  
  • Co-Presenter, “Tax Cuts and Jobs Act: A Sea Change For International Families and Businesses,” External Training Session, London, February 2018.
  • Co-Presenter, “Tax Cuts and Jobs Act: A Sea Change For International Families and Businesses,” Butler Snow Private Client Event, The Law Society, February 2018.
  • Co-Presenter, “Trump and Taxes,” External Presentation, London, November 2017.
  • Co-Presenter, “US Taxation of Non-US (Foreign) Trusts,” External Training Session, London, August 2017.
  • Co-Presenter, “Classification of Trusts in the US,” Guernsey Annual STEP Conference, June 2017.
  • Presenter, “United States: Tax, Estate Planning & the EU Succession Regulation,” The Law Society Private Client Section Cross Border Conference, London, March 2016.
  • Presenter, “So Your Clients Want to Move Their Structures to the United States?”, STEP International Client SIG Conference, December 2015.
  • Presenter, “Planning for the Super Rich – US/UK Planning,” Offshore Investment Conference, London, July 2015.
  • Presenter, “Tackling the Complexities of the Interaction between US / UK Tax Regimes,” Transcontinental Trusts 2015, Geneva, Switzerland, June 2015. 
  • Presenter, “Estate & Tax Planning for the U.S. Citizen in the UK – Expatriation,” IBC Private Client Conference, London, May 2015.
  • Presenter, “The HNW Same Sex Family:  Going Global,” ABA Section of International Law, AIJA Conference, Brighton, April 2015.
  • Presenter, “US/UK Estate Planning and Procedure,” The Law Society Private Client Section Cross Border Conference, London, March 2015.
  • Quoted, "Wealthy Asians dash to ditch US Passports," Asian Investor, December 2014 
  • Co-Author, “ACA Finance Panel,” the American Magazine, December 2014.
  • Presenter, “Catching Up If You Are Out of Compliance,” American Citizens Abroad Town Hall Meeting, London, December 2014.
  • Presenter, “Efficient US/UK Estate and Trust Planning,” IBC Private Client Series Conference, London, November 2014.
  • Presenter, “US/UK Estate Planning and Joint Property Issues,” US Expatriate Tax Year-End Conference, London, October 2014.
  • Quoted, "3,000 Americans ditch their passports," CNN Money, 17 February 2014.
  • Presenter, "US Taxation of Non-US Trusts," US Expatriate Year-End Planning Conference, London, October 2013.
  • Co-Author, "Landmark US Supreme Court Decision May Extend US Tax Benefits to UK Civil Partners," Planning Notes International, Vol. 2013, June 28, 2013.
  • Presenter, "US Tax Issues in Divorce," London, March 2013.
  • Presenter, "US Tax Update and Introduction to Passive Foreign Investment Companies (PFICs)," London, February 2013.
  • Co-Author, "Crossing the Divide: US Tax-saving Opportunities for UK-based Americans," Northwest Resident Magazine, February 2013.
  • Co-Presenter, "US Citizens Abroad: Tax and Legislative Updates in an Ever-evolving World," London, October 2012.
  • Co-Author, "Transatlantic Thinking – Flexible Solutions for Those Facing a Planning Conundrum," April 2012.
  • Presenter, "US Taxation of Trusts (for UK Practitioners)," London, March 2012.
  • Co-Presenter, "US/UK Tax Issues for Americans Residing in the UK," London, 2012.
  • Co-Presenter, "Integrated US/UK Estate Planning," London, 2012 and 2011.
  • Co-Presenter, "The US HIRE Act – Catching Overseas Structures to Ensure Internal Compliance," STEP Conference Isle of Man, November 2010.
  • Co-Author, "Uncompensated Use of Trust Property Taxable to United States Persons," Briefing Note, May 2010.
  • Co-Author, "Death of the US Death Tax? Not all Roses for Families with UK Connections," The Offshore & International Taxation Review, Vol. 14, Iss. 3, 2010.