Collas Crill was instructed to advise the foreign primary beneficiary and protector of a trust, in circumstances where the Guernsey trustee has received Tax Information Exchange Notices (TIEAs) in connection with the trust. There were also difficulties in transacting in the assets of the trust caused by the receipt of the notices.
Collas Crill, working with the Protector and foreign tax counsel, worked with the trustee to challenge the TIEAs, ultimately leading to the complete withdrawal of the notice.