Daniel Feingold
Daniel Feingold
Called in 1983

Daniel is a highly experienced Tax Barrister who has had a wide-ranging career starting at the Bar, continuing at leading City Accountancy and Law firms. Then, for many years, in his own Tax law firm. He brings this extensive perspective to the Bar, which gives him a unique insight into Clients practical and solution-orientated needs that enables the best outcomes with his legal advice.

Daniel works with a range of Clients, including Accountants, Law firms (both Domestic and Foreign), Trust Companies, Multi-Nationals and Tech Startups. (Also, via Direct Access with High Net Work Individuals).

Instructing Us

Practice Overview

Daniel’s practice focuses on a number of key areas, including, until recently, non-domicile planning, restructuring, and advising on the residual issues affecting clients who have remained in, or recently left, the UK following the recent tax changes.

He also advises individuals arriving in or departing from the UK on tax-efficient structuring, including the interaction of relevant Double Tax Treaties and the new UK FIG regime. His practice further encompasses pre-arrival and emigration tax planning, together with offshore trust and company structuring for both inbound and outbound clients, and the related tax implications arising from those arrangements.

Daniel regularly advises both Corporates and Individual Clients. His expertise has helped persuade HMRC to drop or close many Tax Enquiries and Investigations, or settle on beneficial terms for Clients.

Many of these cases have involved issues of Residence, Domicile Offshore Trusts and Companies, and related Complex structures and vehicles.

Daniel has recently been involved in advising on a significant Disguised Remuneration Scheme, through Group Litigation from the First-Tier Tribunal until a refusal of the Court of Appeal to hear their case. Prior to that, Daniel has on many occasions convinced HMRC to drop Legal Action, in advance or just before a Scheduled Hearing.

Including Employee Benefits Trusts, EOTs and Share Schemes. The plethora of tax issues arising in these situations, such as MBOs, MBIs spinning out subsidiaries and using EOTs and Employee Benefits Trusts to mitigate tax.

HMRC investigations into the Individual shareholders and such Trust Structures is now common.

Daniel has reviewed many many Trusts, both Onshore and Offshore over the years and has spent much time drafting and reviewing Trusts to make sure they are valid and effective for tax planning purposes.

When Clients decide to remove Trustees, this often engages legal issues in the relevant jurisdiction.

Daniel has been involved in many such disputes, usually resolving them without costly and lengthy local litigation.

As information and capital flows freely across borders in Global companies, the Tax Authorities are also sharing information between them.

Handling Transfer Pricing investigations to obtain the best outcomes and having good and credible legal documentation at the outset is essential.

Daniel has been involved in advising on and resolving such disputes.
International IP licensing has many tax planning opportunities. Good advice and well-drafted documents are the keys to effective tax structuring, to minimise withholding tax and optimise net returns.

The scope of UK Inheritance Tax for those who leave the UK (the 10 Tax year tail), or for those who remain UK Tax Resident has changed radically. A clear and well-thought review and innovative structuring to mitigate (or a mechanism to fund IHT Inheritance Tax liabilities) is now a growing and regular feature of Daniel’s advisory practice, as many become aware of these new IHT tax liabilities.