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Practice notes
When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets...
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9th Nov
Precedents
This Deed of Appointment is made on [date] by [trustee] of [address] and [trustee] of [address] (the Trustees).Background(A)This Deed is supplemental...
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9th Nov
Practice notes
Duty to distribute to the correct beneficiariesOn the termination of the trust, the trustees are under a duty to distribute the trust assets to the...
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9th Nov
Practice notes
Duration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules against remoteness of vesting and against the...
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9th Nov
Practice notes
Trust litigation has been classified as being of three types:•a dispute as to the trusts on which trustees hold the subject matter of the settlement•a...
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9th Nov
Practice notes
This Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman Islands, see Practice Note: Private...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...
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Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 12th Jan
Practice notes
When trustees are engaged in trust litigation, issues often arise as to how their litigation costs are to be funded. A Beddoe application is the best...
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Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside Chambers 12th Jan
Practice notes
A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or persons (the trustees) to hold...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
The issue of sham is most likely to be raised by the settlor's creditors or former spouse if the settlor is involved in matrimonial proceedings, who...
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9th Nov
Practice notes
Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:•non-distributor offshore funds, or...
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9th Nov
Practice notes
On the face of it, there would appear to be no specific impediment, if there is no reason to suppose that a person is without capacity, in them...
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9th Nov
Practice notes
The term 'relevant property' defines a category of trust property which is subject to a special regime for inheritance tax (IHT). As described in...
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Produced in partnership with Paul Davies of Clarke Willmott 12th Jan
Practice notes
A lifetime gift is a gratuitous transfer of ownership of any property between living persons and not made in expectation of death. In contrast, gifts...
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9th Nov
Practice notes
CertaintyIn order for a settlor to create a private express trust the three certainties must be present, namely:•certainty as to the intention of the...
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9th Nov
Practice notes
What is a blind trust?A blind trust is a trust that is aimed at preventing conflicts of interest arising. Usually, the settlor and beneficiary of the...
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Produced in partnership with Michael O’Sullivan of 5 Stone Buildings 12th Jan

Most recent International content

Practice notes
The risks of cryptoassets from a financial crime, money laundering and terrorist financing perspectiveWhat are cryptoassets?One of the hurdles in...
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14th May
Practice notes
Money Laundering Directive 4 (MLD4)—essentials MLD4, MLD5 and related EU measuresThe Fourth Money Laundering Directive (EU) 2015/849 (MLD4) was...
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14th May
Practice notes
The remittance basis—foreign currency bank accountsForeign currency accounts at non-UK banks are central to the operation of the remittance basis. See...
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14th May
Practice notes
The remittance basis—business investment relief—clawback of exemptionIndividuals can bring foreign income and capital gains into the UK for the...
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14th May
Practice notes
Assistance in collection in tax mattersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period...
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Produced in partnership with David Klass of Hunton Andrews Kurth 14th May
Practice notes
2% SDLT surcharge for non-residentsFrom 1 April 2021, non-UK residents that buy residential property in England and Northern Ireland pay a 2%...
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14th May
Practice notes
The beneficial ownership register of overseas entities that own UK property Corporate transparency is now viewed as an essential element in any...
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13th May
Q&As
Do company directors have to be resident in the country in which the company is registered?Different countries have varying company law requirements...
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13th May
Q&As
What are the requirements and restrictions on the transfer of Jersey registered company shares?For information on the nature and sources of Jersey...
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13th May
Q&As
Coronavirus (COVID-19)—what is the impact of the coronavirus-related restrictions on corporate tax residence and permanent establishments?Any...
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Produced in partnership with Martin Shah 13th May
Q&As
Can a non-UK incorporated company have a UK taxable presence if it has an employee operating in the UK?Whether a single employee working in the UK for...
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13th May
Practice notes
How are individuals taxed on distributions received from companies?This Practice Note explains the rules that apply to distributions made to UK...
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13th May
Practice notes
How are individuals taxed on distributions received from non-UK resident companies prior to 6 April 2016? [Archived]ARCHIVED: This Practice Note has...
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13th May
Practice notes
Offshore receipts in respect of intangible property (ORIP)Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty...
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13th May
Practice notes
When does the UK tax non-resident companies?When a company that is resident outside the UK starts doing business in the UK, it will want to know...
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13th May
Practice notes
Capital gains for connected personsThe capital gains legislation includes specific provisions for persons who are connected with one another. These...
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13th May
Practice notes
UK tax implications of overseas entity classification and distributions from overseas entitiesAn overseas entity may be characterised for UK tax...
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Produced in partnership with Robert Langston of Saffery Champness 13th May
Practice notes
Entity classification case law and HMRC's interpretationIt is necessary to characterise overseas entities for UK tax purposes, as this will determine...
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Produced in partnership with Michael McGowan 13th May
Practice notes
When a company is UK tax residentA company is UK tax resident if it is:•incorporated in the UK (subject to exceptions), or•centrally managed and...
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13th May
Practice notes
Ordinary share capital—what it means and why it matters for UK tax purposesThe concept of ordinary share capital is important for UK tax purposes....
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Produced in partnership with Michael McGowan 13th May

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