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Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

The following Private Client news provides comprehensive and up to date legal information on Supreme Court finds taxpayer had not made deliberate inaccuracy and that staleness is not relevant to discovery (HMRC v Raymond Tooth)

Claimant recovers damages from MIB 24 years after accident—settlement approved, but amount to remain confidential (Johnson v Secretary of State for Transport and MIB)

Private Client weekly highlights—13 May 2021

The following Private Client news provides comprehensive and up to date legal information on Private Client weekly highlights—13 May 2021

Pension body eyes easing retirement plans transfer process

The following Private Client news provides comprehensive and up to date legal information on Pension body eyes easing retirement plans transfer process

Featured Private Client content

Creation of trusts in Scotland

Express creation of trustsA trust is constituted expressly where the owner of property (the truster) transfers property to trustees to hold for...

UK taxation of offshore trusts—inheritance tax

An offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK inheritance tax (IHT) is not dependent on the...

Liferent trusts—Scotland

Liferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both, in the trust property...

Partial deed of revocation of lasting power of attorney

This partial deed of revocation is made on [date] by [donor] of [address].1I granted a Lasting Power of Attorney for [Financial Decisions/Health and...

Practice notes

Situs of assets for succession and IHT

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...

9th Nov

Precedents

Deed of appointment terminating discretionary trust

This Deed of Appointment is made on [date] by [trustee] of [address] and [trustee] of [address] (the Trustees).Background(A)This Deed is supplemental...

9th Nov

Practice notes

Termination of trusts—beneficiaries

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...

9th Nov

Practice notes

Termination of trusts—methods of termination

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...

9th Nov

Practice notes

Trust disputes—court jurisdiction and procedure

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...

9th Nov

Practice notes

Cayman Islands STAR trusts—common uses

This Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman Islands, see Practice Note: Private...

Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan

Practice notes

Bermuda trusts

This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...

Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 12th Jan

Practice notes

Beddoe applications

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...

Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside Chambers 12th Jan

Practice notes

What is an offshore trust?

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...

Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan

Practice notes

Trust disputes—sham trusts

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...

9th Nov

Practice notes

Offshore trusts—offshore income gains (OIGs)

Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:•non-distributor offshore funds, or...

9th Nov

Practice notes

Capacity to litigate

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...

9th Nov

Practice notes

The meaning of relevant property

The term 'relevant property' defines a category of trust property which is subject to a special regime for inheritance tax (IHT). As described in...

Produced in partnership with Paul Davies of Clarke Willmott 12th Jan

Practice notes

Lifetime gifts

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...

9th Nov

Practice notes

Nature and classification of trusts—the three certainties

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...

9th Nov

Practice notes

Creation of trusts—blind trusts

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...

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 perspective

The risks of cryptoassets from a financial crime, money laundering and terrorist financing perspectiveWhat are cryptoassets?One of the hurdles in...

14th May

Practice notes

Money Laundering Directive 4 (MLD4)—essentials

Money Laundering Directive 4 (MLD4)—essentials MLD4, MLD5 and related EU measuresThe Fourth Money Laundering Directive (EU) 2015/849 (MLD4) was...

14th May

Practice notes

The remittance basis—foreign currency bank accounts

The remittance basis—foreign currency bank accountsForeign currency accounts at non-UK banks are central to the operation of the remittance basis. See...

14th May

Practice notes

The remittance basis—business investment relief—clawback of exemption

The remittance basis—business investment relief—clawback of exemptionIndividuals can bring foreign income and capital gains into the UK for the...

14th May

Practice notes

Assistance in collection in tax matters

Assistance in collection in tax mattersIP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period...

Produced in partnership with David Klass of Hunton Andrews Kurth 14th May

Practice notes

2% SDLT surcharge for non-residents

2% SDLT surcharge for non-residentsFrom 1 April 2021, non-UK residents that buy residential property in England and Northern Ireland pay a 2%...

14th May

Practice notes

The beneficial ownership register of overseas entities that own UK property

The beneficial ownership register of overseas entities that own UK property Corporate transparency is now viewed as an essential element in any...

13th May

Q&As

Do company directors have to be resident in the country in which the company is registered?

Do company directors have to be resident in the country in which the company is registered?Different countries have varying company law requirements...

13th May

Q&As

What are the requirements and restrictions on the transfer of Jersey registered company shares?

What are the requirements and restrictions on the transfer of Jersey registered company shares?For information on the nature and sources of Jersey...

13th May

Q&As

Coronavirus (COVID-19)—what is the impact of the coronavirus-related restrictions on corporate tax residence and permanent establishments?

Coronavirus (COVID-19)—what is the impact of the coronavirus-related restrictions on corporate tax residence and permanent establishments?Any...

Produced in partnership with Martin Shah 13th May

COVID-19

Q&As

Can a non-UK incorporated company have a UK taxable presence if it has an employee operating in the UK?

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...

13th May

Practice notes

How are individuals taxed on distributions received from companies?

How are individuals taxed on distributions received from companies?This Practice Note explains the rules that apply to distributions made to UK...

13th May

Practice notes

How are individuals taxed on distributions received from non-UK resident companies prior to 6 April 2016? [Archived]

How are individuals taxed on distributions received from non-UK resident companies prior to 6 April 2016? [Archived]ARCHIVED: This Practice Note has...

13th May

Practice notes

Offshore receipts in respect of intangible property (ORIP)

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...

13th May

Practice notes

When does the UK tax non-resident companies?

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...

13th May

Practice notes

Capital gains for connected persons

Capital gains for connected personsThe capital gains legislation includes specific provisions for persons who are connected with one another. These...

13th May

Practice notes

UK tax implications of overseas entity classification and distributions from overseas entities

UK tax implications of overseas entity classification and distributions from overseas entitiesAn overseas entity may be characterised for UK tax...

Produced in partnership with Robert Langston of Saffery Champness 13th May

Practice notes

Entity classification case law and HMRC's interpretation

Entity classification case law and HMRC's interpretationIt is necessary to characterise overseas entities for UK tax purposes, as this will determine...

Produced in partnership with Michael McGowan 13th May

Practice notes