His case list, confidential, underlines a wide experience in isolating the real issues and resolving the defined problems to the client's advantage. 

Peter’s ability to redeem, restore and modernise historic and existing structures at risk of failure owing to legislative regulatory or fiscal changes is a valued contribution to professionals and clients alike. 

His experience and advice will enable you to successfully anticipate future developments. 

Peter’s experience in International and European taxation is based upon a fundamental training obtained at a time when the foundations of current thinking in these areas were being defined, and subsequently implemented and developed. 

Peter's expertise in pure applied law and the effective use of conflict and Private International Law principles has led to significant changes in the perception of how to manage successions under the EU Succession Regulation n° 650/2012. 

In particular, he has designed a method whereby French forced heirship rules over French property can be disapplied in successions between the United Kingdom, the Channel Islands and France. This affects first and second unions where the rights of the surviving spouse need protection, and also in first union/marriage situations where the constitution of a usufruit needs to be distinguished from a deemed settlement under s. 43 ITA 1984. 

Peter's work in defining what trusts are caught and which ones are not by the French 2011 legislation is also well known. 

Peter's experience in Inheritance Tax, droits de mutation à titre gratuit (donation et succession) and Wealth Tax between the United Kingdom and France is well documented. 

He has been successful in having HMRC admit that their treatment of French usufruits as interests in possession over settled property in their April 2013 Newsletter was wrong - obtaining a tax credit reimbursement in the process. His publications have served as a framework for other senior Barristers’ advice. 

Examples of previous instructions

• English family law, French heirship and succession in France.
• Advising a family on whether a Trust fell foul of the French 2011 legislation: advice confirmed by a decision of Tribunal de 1er instance de Paris and upheld on appeal to the Cour d’appel.
• Issues of domiciles of dependency prior to the 1973 Act and reversion to the dependant spouse’s domicile of origin when the husband deceased prior to 1974.
• Successful negotiations with HMRC on French Usufruits. Use of the notion of jouissance.
• Treatment of foreign dismemberments for SDLT relief on UK property purchases.
• Advising on the tax and compliance treatment of English LLPs in a Franco-British investment context.
• Assisting the Centre notarial de droit Européen at Lyon in implementing a system for succession to for French immovables using the pre-1897 English common law jurisdictional rules when the succession is governed by English law.
• Intervention with Taxud3 of the European Commission on a breach of the Freedom of movement of capital.
• SDLT: classification of usufruit/nue-propriété dismemberments as not constituting apparent ownership in the context of the Temporary Relief scheme and First Time Buyer’s Relief.
  

Peter’s present and past successes in international tax and legal negotiations with Tax Authorities - HMRC, DGFIP DVSF, IRS - evidence conceptual discipline, presentational ability and a firm grasp of both British and French fiscal principle and the economics underlying fiscal policy and Tax Treaty provisions. 

His practice is one of the few Revenue and Chancery Bar chambers dedicated to providing these specific onshore and offshore tax and legal services.