Stephen Parnham

This Practice Note explains some of the more common inheritance tax (IHT) planning schemes which were popular until the 2000s and which have largely been rendered ineffective for IHT purposes by anti-avoidance legislation. It covers the historical use of arrangements known as Ingram schemes, Eversden schemes, reversionary lease schemes and home loan or double trust schemes. It also considers the current tax position for some schemes which have not yet been unwound.

This Practice Note describes the pre-owned asset tax (POAT or pre-owned asset charge), which is the annual income tax charge on the continued benefit an individual enjoys from an asset that has been given away. POAT was introduced as an anti-avoidance measure in the Finance Act 2004, largely in response to inheritance tax avoidance schemes. The Practice Note also covers the exclusions and exemptions from charge.

This Practice Note, written by Stephen Parnham of Stephen Parnham Taxation Limited, looks at the concept of shadow directors in the context of offshore tax planning and the extent to which such directors may be subject to benefit in kind charges arising under the benefits code in the Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). It focuses on the meaning of shadow director, the charge on living accommodation, the charge on subsidised loans (also known as beneficial loan arrangements) and the residual charge.

This Practice Note written by Stephen Parnham of Stephen Parnham Taxation Limited covers the income tax and capital gains tax (CGT) implications for high net worth individuals (HNWIs), including remittance basis users, of becoming temporarily non-resident after 5 April 2013. Some planning points are also covered.

ARCHIVED: This Practice Note has been archived and is not maintained. This Practice Note is an introduction to the inheritance tax (IHT), income tax and capital gains tax (CGT) regimes affecting UK resident non-domiciliaries and the basic planning opportunities available to them, including pre-entry planning, excluded property trusts, home ownership, the remittance basis and applicable anti-avoidance legislation. Planning prior to 6 April 2008 and the impact of changes to the taxation of offshore trusts in 2017 and 2018 is also briefly examined.