2020-21—Budget and Finance Bill

This subtopic draws together content on the fiscal events throughout the tax year 2020–21 starting with the Summer economic statement on 8 July 2020, through release

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Latest Private Client News

HMRC publishes minutes of subgroup meeting on changes to taxation of non-doms

HMRC has formed a time-limited joint subgroup comprising members of its Wealthy External Forum and Capital Taxes Liaison Group focusing on changes to the taxation of non-UK domiciled individuals. The subgroup, aims to facilitate collaboration between HMRC and representative bodies to support the development of guidance and tools following the Autumn Budget 2024 announcements. The group will meet approximately every four weeks to discuss implementation strategies, provide feedback on draft guidance, and enhance working relationships between HMRC, customers, and their representatives. Minutes of the meeting held on 18 November 2024 have been published.

HMRC updates form IHT100f

HMRC has released a new version of the IHT100f form, which is used to notify HMRC about events affecting property that holds an exemption from inheritance tax or estate duty. The amendments to the updated version include: the declaration on page six only requires the trustee's signature followed by a signature block designated exclusively to that of the trustee and lastly, the return address as well as contact details listed on page seven have been changed.

Release from reverse indemnity undertakings (Knight v Barnsley)

Private Client analysis: Her Honour Judge Hilder determined that the Court of Protection did have jurisdiction to determine a dispute over the claimant’s deputy’s release from reverse indemnity undertakings, on the basis that this was the method of resolution the parties had agreed to in the settlement agreement that provided for the reverse indemnity undertakings, albeit she doubted whether it was ‘right’ for civil disputes to be brought to the Court of Protection in this way. She also considered the potential tension in the Court of Protection’s role in such cases and adopted an approach to determining the dispute that aimed to ameliorate that tension whilst maintaining the Mental Capacity Act 2005 (MCA 2005)—mandated focus on P’s best interests. Written by Katherine Hampshire, barrister at Serjeants’ Inn Chambers.

Private Client weekly highlights—12 December 2024

This week’s edition of Private Client highlights includes: (1) JTC Employer Solutions Trustee Ltd v Garnett, in which the High Court granted rescission of deeds of appointment executed for EBTs on grounds of mistake; (2) Oldham MBC v KZ, in which the Court of Protection authorised a care plan for a deaf man with fluctuating capacity; (3) Rupert Grint v HMRC, where the FTT held that sales of occupation income provisions applied to a capital sum received by the taxpayer on the incorporation of his business; (4) Tianrui IHC v China Shanshui Cement Group Ltd (Cayman Islands), a Privy Council decision on a shareholder’s personal standing to challenge the dilution of its shareholding; (5) Aabar Holdings S.A.R.L v Glencore plc, a decision which casts doubt on a shareholder’s entitlement to see a company’s privileged documents; and (6) HMRC publishes minutes of the November meeting of joint HMRC/industry working group on the non-dom changes.