Non-resident individuals

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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
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
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
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 Non-resident individuals content

Practice notes
This Practice Note briefly summarises the main UK taxes which may apply to non-UK resident individuals, including income tax, capital gains tax (CGT),...
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20th Apr
Practice notes
The concepts of residence and domicile are used to establish the extent of an individual's liability to UK taxation. This Practice Note provides a...
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9th Apr
Practice notes
Generally, where an overseas client owns an asset in the UK, their primary concern will be UK inheritance tax (IHT). For UK residential property,...
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Produced in partnership with Emma Pearce of Pump Court Tax Chambers and Laura Poots of Pump Court Tax Chambers 9th Apr
Practice notes
Overseas clients (ie non-UK resident and non-UK domiciled) may wish to benefit individuals who are resident, or may become resident, in the UK. Their...
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Produced in partnership with Emma Pearce of Pump Court Tax Chambers 9th Apr
Practice notes
The Practice Note deals with the income tax and capital gains tax (CGT) issues arising for individuals who are not UK resident and not domiciled in...
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Produced in partnership with Emma Pearce of Pump Court Tax Chambers 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
STOP PRESS relating to property rich collective investment vehicles and certain investors: HMRC consulted until 16 December 2020 on regulations that...
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6th Apr
Practice notes
CORONAVIRUS (COVID-19): CIOT has asked the government to consider delaying changes to principal private residence relief (PPR) (which are due to take...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 12th Mar
Q&As
The enterprise investment scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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22nd Jan
Q&As
The general rule is that trustees of bare trusts (that is, where beneficiaries have an absolute entitlement to capital and income) are not required to...
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22nd Jan
Precedents
Key points•the concept of residence is used to establish the extent of an individual's liability to UK income tax and capital gains tax (CGT)•an...
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29th Nov
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
Broadly, UK diplomats serving overseas are subject to the rules regarding residence and domicile for UK tax purposes, as are set out in: Residence of...
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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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