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Nate Borrie is a leading tax solicitor in Washington, with over 30 years of legal practice.
About Me
Nate Borrie is a barrister with a strong advisory practice and equally extensive litigation experience before English courts, foreign courts and the Privy Council. He is a former chair of the Revenue Bar Association and the author of numerous books on taxation. He is particularly strong on IHT planning and offshore tax issues.
With over four decades of experience advising on all aspects of UK and International tax law, Rosner provides expert guidance across the full spectrum of personal and corporate tax matters, including tax planning, HMRC investigations, and complex compliance issues.
Rosner has been advising individuals, businesses, and trustees on UK tax matters for more than 30 years.
He has particular expertise in advising high-net-worth individuals, business owners, and family offices on strategic tax planning and structuring. Rosner also acts for corporates on matters such as corporate reorganisations, employee share schemes, and VAT. His work frequently includes negotiating with HMRC and resolving disputes efficiently and discreetly.

Our Vision
To be recognised as a leading authority in UK tax law—trusted by individuals and businesses alike for delivering expert, forward-thinking advice with integrity and precision.
Our Mission
Our mission is to provide clear, strategic tax legal advice that protects our clients’ interests and delivers real value. We guide individuals and businesses through complex tax matters with confidence and care.
Core Values
We are committed to expert, honest, and client-focused tax advice delivered with professionalism and discretion. Our responsive approach ensures practical solutions tailored to every client’s needs.
Cases
- R (M.Sport Limited v HMRC) [2021] EWCA Civ 561 (Court of Appeal)
- Le Roux Zeeman & Ors v HM Revenue and Customs [2020] EWHC 794
- Revenue and Customs Commissioners v Loyalty Management UK Ltd [2008] STC 59, [2007] EWCA Civ 965, and 151 Sol Jo 1300
- BUPA Hospitals Ltd and another v Customs and Excise Commissioners
- Greenalls Management Ltd v Customs & Excise Commisssioners [2005] UKHL 34 (House of Lords)
- Jerome v Kelly (Inspector of Taxes)
- Red Discretionary Trustees v Inspector of Taxes; Spc 397 [2004] STC (SCD) 132
- Mount Murray Country Club Ltd. And Ors v. Macleod and Ors
- Jerome v Kelly (Inspector of Taxes)
- Unilever (UK) Holdings Ltd v Smith (Inspector of Taxes)
- Jerome v Kelly (Inspector of Taxes)
- Unilever (UK) Holdings Ltd v Smith (Inspector of Taxes)
- Stewart and another (t/a GT Shooting) v Customs and Excise Commissioners
- Regina v Dimsey [2001] UKHL 46 Regina v Allen [2001] UKHL 45
- Jerome v Kelly (Inspector of Taxes)
- Unilever (UK) Holdings Ltd v Smith (Inspector of Taxes)
- NMB Holdings Ltd v Secretary of State for Social Security
- Parker Hale Ltd v Customs and Excise Commissioners
- Regina v. Dimsey; Regina v. Allen
- Schuldenfrei v Hilton (Inspector of Taxes)
- REGINA v. DIMSEY ; REGINA v. ALLEN
- Unigreg Ltd v Commissioners of Customs and Excise
- Memec plc v Commissioners of Inland Revenue
- Steele (Inspector of Taxes) v EVC International NV (formerly European Vinyls Corp (Holdings) BV)
- R v Inland Revenue Commissioners, ex parte Unilever plc and related application
- R v Inland Revenue Commissioners, ex parte Unilever plc and related application
- Marshall (HM Inspector of Taxes) v Kerr
- STANTON (INSPECTOR OF TAXES) APPELLANT AND DRAYTON COMMERCIAL INVESTMENT CO. LTD. RESPONDENTS
Associations & Memberships
- Chairman of the Revenue Bar Association of England and Wales 2001-05
- Bencher of the Middle Temple (Elected 1999)
- Council Member of the Chartered Institute of Taxation and Chartered Tax Adviser (from 1999)
- Non-Executive Fellow of St Edmund Hall, Oxford
- Consulting Editor of The Offshore Taxation Review, The Personal Tax Planning Review, The Corporate Tax Review and The E.C. Tax Journal; Chairman of the Advisory Editorial Board of The Charity Law and Practice Review.
What Our Clients Say

Rosner’s knowledge of tax law is simply awesome and he is very robust when litigating, which puts the opponent on the back foot and gives the lay client every confidence in his legal team.
John Ngunoe

Extremely experienced and somebody you can rely upon to come at things from a different angle to get results.
Jessica Cole

He is fantastic. He is very, very thorough and a very bright tax lawyer. He is in a class of his own.