Offshore trusts—taxation

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Practice notes
Liferent trusts—ScotlandLiferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both,...
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Produced in partnership with Peter Murrin of Turcan Connell 19th May
Practice notes
Capital gains tax issues on deathSTOP PRESS: The Office of Tax Simplification published its first report on the review of capital gains tax (CGT) on...
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19th May
Practice notes
Nature and classification of trusts—the three certaintiesCertaintyIn order for a settlor to create a private express trust the three certainties must...
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19th May
Practice notes
CGT—giftsA gift of an asset is a disposal for capital gains tax (CGT) purposes. It can, therefore, trigger a CGT charge on the gain deemed to have...
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Produced in partnership with Laura Poots (Barrister) of Pump Court Tax Chambers 19th May
Precedents
This Deed OF REVOCATION is made on [date] by me [name of donor] of [address of donor].This Deed provides:1Revocation...
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19th May
Practice notes
Trustees—removal of trusteesA trustee may be removed against their will in any of the following ways:•under an express power in the trust...
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19th May
Practice notes
Creation of trusts—blind trustsWhat is a blind trust?A blind trust is a trust that is aimed at preventing conflicts of interest arising. Usually, the...
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Produced in partnership with Michael O’Sullivan of 5 Stone Buildings 19th May
Practice notes
The Cy-près doctrineFORTHCOMING CHANGE: On 22 March 2021, the government published its response  to the Law Commission’s report of 14 September 2017,...
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19th May
Practice notes
Relief for income tax lossesReliefs entitle taxpayers to reduce the amount of income tax payable. When calculating liability to income tax, a taxpayer...
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19th May
Practice notes
Assessment for residential accommodationCoronavirus (COVID-19): The content of this Practice Note is temporarily affected by the coronavirus...
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19th May
Practice notes
Capacity to litigateOn the face of it, there would appear to be no specific impediment, if there is no reason to suppose that a person is without...
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19th May
Practice notes
Termination of trusts—methods of terminationDuration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules...
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19th May
Practice notes
Costs and expenses in the Court of ProtectionThere are court fees and disbursements which will be payable by all applicants on making a new...
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19th May
Practice notes
Trust disputes—court jurisdiction and procedureTrust litigation has been classified as being of three types:•a dispute as to the trusts on which...
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19th May
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...
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19th May
Practice notes
Statutory Wills—Court of Protection applicationsWhat is a statutory Will?Where a person is incapable of making a valid Will for themselves, the Court...
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19th May

Most recent Offshore trusts—taxation content

Q&As
When a settlement that is a 'protected settlement' for the purposes of capital gains tax becomes a 'qualifying settlement', how are the stockpiled...
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31st Jul
Practice notes
Offshore trusts—capital payments to UK resident non-domiciliaries and applicable reliefsAs discussed in the UK resident non-domiciliaries—tax planning...
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31st Jul
Practice notes
Offshore trusts—attribution of income to settlorsThis Practice Note considers the provisions of part 5, sections 619–648 of the Income Tax (Trading...
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31st Jul
Practice notes
Planning for becoming deemed domiciled under the 15-year ruleFinance (No 2) Act 2017 (F(No 2)A 2017) introduced several tax reforms in relation to...
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31st Jul
Practice notes
Offshore trusts—benefits and capital payments to UK resident beneficiariesIncome, capital gains and offshore income gains (OIGs) of an offshore trust...
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31st Jul
Practice notes
Management and control of trustsKey considerationsIn order to access the benefits of having an offshore trust, it is vital to ensure that the...
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31st Jul
Practice notes
UK taxation of offshore trusts—income tax and capital gains taxAn offshore trust is any non-UK resident trust. The trustees of offshore trusts have...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 31st Jul
Practice notes
Tax position of non-resident trustsThis Practice Note was originally drafted by Owen Clutton of Macfarlanes LLP but is now maintained by Lexis®PSL...
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31st Jul
Practice notes
Characterisation of trust distributions for tax purposesThe tax treatment of a distribution from a trust in the hands of the recipient is determined...
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31st Jul
Practice notes
Offshore trusts—the trustee borrowing rules—Sch 4B and Sch 4C TCGA 1992The trustee borrowing rules were introduced in 2000 to counter a specific...
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Produced in partnership with Dhana Sabanathan of Winckworth Sherwood 31st Jul
Practice notes
Changes to the taxation of offshore trusts from 6 April 2017This Practice Note describes the new income tax and capital gains tax (CGT) regime which...
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31st Jul
Practice notes
Offshore trusts—rebasing electionsBackgroundPrior to 6 April 2008, individuals who were UK resident and non-UK domiciled (RND) could benefit from...
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Produced in partnership with Suzanna Harvey of Burges Salmon 31st Jul
Practice notes
Taxation of offshore trusts—non-domiciled and deemed domiciled settlorsSignificance of settlor’s domicile for offshore trustsThe extent of a trust’s...
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31st Jul
Practice notes
Tax implications of a mistake on a change of trusteesIt is vital that the correct procedure is followed when there is a change of trustees. Depending...
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Produced in partnership with Katharina A. Byrne. 31st Jul
Practice notes
UK taxation of offshore trusts—inheritance taxAn offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 31st Jul
Practice notes
Offshore trust complianceThis Practice Note is based on material originally produced by Tolley in partnership with Milestone International Tax...
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31st Jul
Practice notes
Glossary of UK trust and taxation law terms for international clientsAAdministrationThe process starting on the date of the deceased's death and...
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31st Jul
Practice notes
Offshore trusts—transfers between settlements—offshore income gains (OIGs) and s 1(3) amountsCapital payments are generally taxed by matching them...
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31st Jul
Practice notes
Offshore trusts—attribution of gains to settlorsBrexit: As of exit day (31 January 2020) the UK is no longer an EU Member State. However, in...
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31st Jul

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