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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
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
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 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
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 Offshore companies content

Practice notes
This guide sets out the requirements for executing deeds in various international jurisdictions. The table provides a quick-reference summary of the...
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Produced in partnership with Diego Krischcautzky of Marval, O’Farrell & Mairal 13th 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 Robert Langston of Saffery Champness 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 Robert Langston of Saffery Champness 9th Apr
Practice notes
This Practice Note is about the rules that can impose a charge to tax on UK persons holding interests in a non-UK resident company if that company...
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9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The way in which individuals are taxed on distributions was substantially changed...
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9th Apr
Practice notes
When a company that is resident outside the UK starts doing business in the UK, it will want to know whether and to what extent the activities of that...
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9th Apr
Practice notes
Coronavirus (COVID-19): For information on the inadvertent creation of permanent establishments as a result of the coronavirus pandemic, see Q&A:...
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9th Apr
Practice notes
The concept of ordinary share capital is important for UK tax purposes. This Practice Note sets out the key tax reliefs that usually require ordinary...
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Produced in partnership with Michael McGowan 9th Apr
Practice notes
Summary of tax considerationsThe concept of a close company is intended to capture those companies that are closely controlled (ie by the owners and...
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9th Apr
Practice notes
The capital gains legislation includes specific provisions for persons who are connected with one another. These provisions can be divided into two...
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9th Apr
Practice notes
Since 6 April 2019, a person that is neither UK tax resident nor resident in a full treaty territory (ie not resident in a territory with which the UK...
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9th Apr
Practice notes
An overseas entity may be characterised for UK tax purposes as transparent or opaque. This Practice Note explains how such classification will affect...
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Produced in partnership with Robert Langston of Saffery Champness 9th Apr
Practice notes
Each jurisdiction applies its own domestic law test to determine when a company is treated as tax resident there. A company can be resident in more...
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9th Apr
Practice notes
What is a Cayman Islands foundation company?The Foundation Companies Law, 2017 has been in force now for three years, enabling the establishment of...
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Produced in partnership with Anthony Partridge of Ogier, Cayman Islands and Wisdom Hon of Ogier, Hong Kong 9th Apr
Practice notes
From April 2019, the profit fragmentation rules aim to prevent UK-resident individuals, including individual members of a partnership, and UK-resident...
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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
ARCHIVED: This Practice Note gives an overview of the non-resident capital gains tax (NRCGT) charge that applied to certain non-UK resident persons...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 9th Apr
Practice notes
This Practice Note summarises the changes to the excluded property rules from 6 April 2017 introduced by the Finance (No 2) Act 2017 (F(No 2)A 2017)....
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Produced in partnership with James Brockhurst of Forsters LLP 9th Apr
Practice notes
When looking at the definition of chargeable transfers and transfers of value in the Inheritance Tax Act 1984 (IHTA 1984), it is perhaps not...
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Produced in partnership with Katya Vagner of PwC 9th Apr
Practice notes
This Practice Note considers shadow directors of offshore companies and the extent to which such directors may be subject to benefit in kind charges...
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Produced in partnership with Stephen Parnham 9th Apr

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