Offshore tax evasion

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Contentious probate—section 9 of the Wills Act 1837—capacity—knowledge and approval—pleading (Gardiner v Tabet)

The following Private Client news provides comprehensive and up to date legal information on Contentious probate—section 9 of the Wills Act 1837—capacity—knowledge and approval—pleading (Gardiner v Tabet)

Taxation of contractor loans (Hoey v HMRC)

The following Private Client news provides comprehensive and up to date legal information on Taxation of contractor loans (Hoey v HMRC)

Private Client weekly highlights—15 April 2021

The following Private Client news provides comprehensive and up to date legal information on Private Client weekly highlights—15 April 2021

UT rules on construction of closure notices (Daarasp LLP and Betex LLP)

The following Private Client news provides comprehensive and up to date legal information on UT rules on construction of closure notices (Daarasp LLP and Betex LLP)

Featured Private Client content

Notaries and notarisation—notarisation

The principles of the notarial act are that it is:•an act of the notary and not of the parties named in the document•a record of a fact, event or...

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...

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...

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...

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

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

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

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

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

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

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

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

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

Trustees—power of advancement

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...

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

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

Precedents

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...

9th Nov

Practice notes

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...

Produced in partnership with Peter Murrin of Turcan Connell 12th Jan

Scottish Law

Practice notes

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...

Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 12th Jan

Practice notes

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...

Produced in partnership with Yvonne Evans, Law Lecturer, Solicitor (non-practising), TEP, University of Dundee 12th Jan

Scottish Law

Most recent Offshore tax evasion content

Q&As

What are the differences between the two proposed corporate offences involving the facilitation of tax evasion, who can commit the offences and what defences are going to be available?

DisclaimerThis Q&A is based on the draft Criminal Finances Bill (CFB) 2017 as at 23 April 2017, at which point it had not received Royal Assent. For...

Produced in partnership with James Brockhurst of Gowling WLG 19th Apr

Q&As

Do type C trusts in the Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020, SI 2020/991, reg 45ZA(1)(c) only relate to interests in UK land acquired on or after 6 October 2020? Will a Jersey Property Unit Trust holding UK real estate but with no UK tax liability have to register only where the UK real estate was acquired from 6 October 2020 or will it have to comply with the registration provisions on a retrospective basis?

The Money Laundering and Terrorist Financing (Amendment) (EU Exit) Regulations 2020 (MLR 2020), SI 2020/991, reg 45ZA(1)(c) provides:'(c) a “type C...

16th Apr

Practice notes

Trusts—record-keeping and disclosure of beneficial ownership information

FORTHCOMING CHANGE: The EU Fifth Anti-Money Laundering Directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force...

16th Apr

Practice notes

Money Laundering Regulations 2017—impact on trustees

FORTHCOMING CHANGE: The EU Fifth Anti-Money Laundering Directive (5MLD) was published in the EU official journal on 19 June 2018 and came into force...

16th Apr

Practice notes

Disclosable cross-border tax arrangements—DAC 6

FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements rules was significantly reduced with effect...

12th Apr

In-house

Practice notes

US: FATCA—foreign financial institutions (FFIs)

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr

Practice notes

FATCA in the UK—the UK:US Intergovernmental Agreement: an outline

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 9th Apr

In-house

Practice notes

US: FATCA—tax credits and excluded obligations

The Foreign Account Tax Compliance Act (FATCA) has three core elements:•enhanced due diligence•broader information reporting, and•a potential...

Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr

Practice notes

US: Foreign Account Tax Compliance Act (FATCA)—summary

The Hiring Incentives to Restore Employment Act (the HIRE Act) include provisions that give the US Internal Revenue Service (the IRS) administrative...

Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr

Practice notes

Tax—FATCA tracker

This tax 'tracker' tool displays the current status of both US FATCA and UK FATCA intergovernmental agreements (IGA).The tracker is split into five...

9th Apr

Practice notes

UK Crown Dependency/Overseas Territory Agreements (CDOT)—FAQs

What are the CDOT agreements?The UK entered into agreements with its three Crown Dependencies (CDs) (Guernsey, Jersey and the Isle of Man), together...

Produced in partnership with Ali Kazimi of Hansuke 9th Apr

Practice notes

Directive for administrative cooperation in the field of taxation (DAC)—FAQs

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s...

Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 9th Apr

Practice notes

UK-Switzerland Tax Co-operation Agreement [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.On 6 October 2011, the governments of Switzerland and the UK signed an agreement...

9th Apr

Practice notes

Tax Information Exchange Agreements

This Practice Note provides a brief introduction to Tax Information Exchange Agreements (TIEAs). For a general introduction to the subject of tax...

9th Apr

Practice notes

Offshore penalties, sanctions and criminal offences—outline

STOP PRESS: The All-Party Parliamentary Group on Anti-Corruption & Responsible Tax, which was established in June 2020 is currently researching more...

9th Apr

Practice notes

Requirement to correct offshore tax non-compliance

What is the requirement to correct?The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance...

9th Apr

Practice notes

Offshore tax evaders—offshore penalties and other civil sanctions

This Practice Note considers:•requirement to correct and failure to correct penalties•penalties for offshore matters or offshore transfers•offshore...

Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons 9th Apr

Practice notes

Automatic exchange of information—outline

STOP PRESS: The government has enacted amending regulations that significantly restrict the scope of the UK’s disclosable arrangements rules (which...

9th Apr

Practice notes

Crown Dependency Disclosure Facilities [Archived]

ARCHIVED: This Practice Note has been archived and is not maintained.In October 2013, the Isle of Man, Jersey and Guernsey each signed...

9th Apr

Practice notes

Glossary of UK trust and taxation law terms for international clients

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...

9th Apr

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Offshore tax evasion

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Latest Private Client News

Contentious probate—section 9 of the Wills Act 1837—capacity—knowledge and approval—pleading (Gardiner v Tabet)

Taxation of contractor loans (Hoey v HMRC)

Private Client weekly highlights—15 April 2021

UT rules on construction of closure notices (Daarasp LLP and Betex LLP)

Featured Private Client content

Notaries and notarisation—notarisation

Creation of trusts—blind trusts

Nature and classification of trusts—the three certainties

Lifetime gifts

Most recent Offshore tax evasion content

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