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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
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
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
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
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
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
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
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
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
Where a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married under that date but is required...
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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
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 partial deed of revocation is made on [date] by [donor] of [address].1I granted a Lasting Power of Attorney for [Financial Decisions/Health and...
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9th Nov
Practice notes
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...
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Produced in partnership with Peter Murrin of Turcan Connell 12th Jan
Practice notes
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...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 12th Jan
Practice notes
Express creation of trustsA trust is constituted expressly where the owner of property (the truster) transfers property to trustees to hold for...
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Produced in partnership with Yvonne Evans, Law Lecturer, Solicitor (non-practising), TEP, University of Dundee 12th Jan

Most recent Individuals leaving the UK content

Practice notes
Given the ever increasing global mobility of employees, employers could be regularly required to understand and comply with numerous legislative...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes
There are different categories of overseas pension schemes, with various layers of requirements. These include:•Overseas Pension Schemes...
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Produced in partnership with Stephenson Harwood and Fraser Sparks of PwC 9th Apr
Practice notes
Why use a QROPS?In practice, many Qualifying Recognised Overseas Pension Schemes (QROPSs) are personal pension schemes or retirement annuities that...
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Produced in partnership with Sean McNulty of Blake Morgan 9th Apr
Practice notes
IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...
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Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 9th Apr
Practice notes
IntroductionThis Practice Note discusses the taxation of internationally mobile employees and directors in relation to securities options (options)...
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Produced in partnership with Jeremy Edwards of Baker McKenzie and Gill Murdoch 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.Following recommendations of the Office of Tax Simplification and an HMRC...
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9th Apr
Practice notes
Temporary non-residence—statutory anti-avoidance ruleThe statutory test for non-residence includes a general anti-avoidance rule to counteract tax...
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Produced in partnership with Stephen Parnham 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.Temporary non-residence conditionsThe pre-2013 rules apply if an individual's...
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9th Apr
Practice notes
AAdministrationThe process starting on the date of the deceased's death and ending on the date the deceased's affairs are finalised by his personal...
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9th Apr
Practice notes
CORONAVIRUS (COVID-19) UPDATE: Through Pension Schemes Newsletter 128 and Pension Schemes Newsletter 121, HMRC announced that it will cancel penalties...
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Produced in partnership with Sean McNulty of Blake Morgan 31st Mar
Practice notes
This Practice Note explains some of the tax traps and opportunities for people leaving the UK. It is an outline, and specific advice may need to be...
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15th Mar
Practice notes
This Practice Note deals with the application of the residence rules to people leaving the UK after 5 April 2013.The UK’s first formal tax residency...
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10th Mar
Practice notes
Residence usually refers to the individual's tax status on a year by year basis, however it may be possible to split the tax year into periods of UK...
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23rd Feb
Q&As
The following facts have been assumed:•the UK citizen in question had a domicile of origin in one of the home nations of the UK•the reference to the...
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29th Nov
Q&As
FORTHCOMING CHANGE: proposed temporary relaxation of the statutory residence test: On 9 April 2020, a letter from the Chancellor to the Chair of the...
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29th Nov

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