Jeffrey Cohen

Senior Associate

Head of Wealth and Succession Planning team

Testimonials

About

Jeffrey is Head of the Private Client department of Mackrell.Solicitors ’s London office. He is a highly experienced private client lawyer and focuses on all aspects of private client law, wealth management, tax and trust law including estate and inheritance tax planning. Jeffrey also deals with contentious probate and trust issues.

He is also experienced in drafting wills, probate administration, establishment and running of trusts including charity trust foundations, court of protection work, powers of attorney and offshore tax planning.

In 2013, Jeffrey was recommended in the Legal 500 directory of legal services providers. In it he “is recommended for his experience in Inheritance Tax and Capital Gains Tax” and has also held recognition in the Spear’s 500 guide for the last several years based upon his work within the firm.

Jeffrey is a member of the Society of Trust and Estate Practitioners (STEP) and is often asked to speak on trusts and tax planning. Jeffrey runs a number of tax seminars and advises many intermediaries, such as banks and IFAs, on Inheritance Tax Planning.

He was also part of the team shortlisted in the British Wills & Probate Awards as best Solicitor Firm of the Year. Jeffrey has contributed and been featured in a number of publications in the past, sharing his knowledge on a wide range of tax law and estate planning matters.

Professional qualifications and memberships

  • Solicitor, England and Wales
  • Member of STEP

Publications

Recent work

  • Acted for a person who was terminally ill.  They had a complex estate with some assets having a large amount of capital gains and some of them without such gains.  As his estate was more than £2 million he would not have qualified for the residence nil rate band.  However, by restructuring the estates between himself and his wife we were able to reduce the value of his estate to below the £2 million threshold.  By transferring assets which had no gain to his spouse and by his spouse transferring to him those assets which had substantial gains that means that on his death those gains would then be wiped out.  His wife will then inherit at the new base value and she could then make distributions to the children and grandchildren, subject to her surviving seven years.  This will therefore save a very substantial amount, not only in inheritance tax but also in capital gains, which otherwise would have been triggered if he had tried to dispose of those assets.
  • A family held a large portfolio of properties but they were all in their personal names, some with mortgages.  We restructured the various holdings by creating a new vehicle which was tax neutral and also by creating a new company.  In effect, the properties which were mortgaged were transferred to the company so that it could then claim mortgage relief.  The other assets were held within the new structure, being an limited liability partnership (LLP) and thus not triggering any tax.  Provided that the family run it as a proper business going forward this will save a substantial amount of inheritance tax in respect of those properties which are now held within the LLP and company which is a partner of the LLP.
  • A person held a business.  Under the terms of his Will we gifted the business, which qualified for being free of inheritance tax, to a trust.  We then had an Option Agreement under which the surviving spouse could buy those shares from the cash in the rest of the estate.  When that takes place the trust will have cash and although it will pay inheritance tax it will only pay inheritance tax at the rate of 6% every 10 years as opposed to 40%.  Further, the surviving spouse, having bought the shares, provided he/she survives two years that would again qualify for full business property relief.  This will therefore gain double business property relief on the asset and at the same time save a very substantial amount of inheritance tax.
  • Advising an international family who held substantial assets in the USA with regard to inheritance tax, taking into account the deemed domicile rules and also the recent changes in the way that HMRC allow additions and changes to offshore trusts.  By careful planning before deemed domicile rules to change the trust and to add further offshore assets and thus mitigate the potential inheritance tax which otherwise would apply.

Podcasts and media