Tax avoidance, evasion and non-compliance

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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 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
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 Tax avoidance, evasion and non-compliance content

Practice notes
FORTHCOMING CHANGE: As described in this Practice Note, the scope of the UK’s disclosable arrangements rules was significantly reduced with effect...
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5th May
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 introduces a new ‘financial institution notice’ (FIN) that can require financial institutions to provide...
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5th May
Practice notes
FORTHCOMING CHANGE: As announced at Budget 2018, draft legislation to be included in Finance Bill 2019–20 was published on 11 July 2019 and includes a...
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4th May
Practice notes
There are various options open to HMRC when it suspects that tax has not been paid, or has been underpaid. These include:•issuing a determination—this...
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28th Apr
Q&As
Directive on criminalising money launderingOn 12 November 2018, the Directive (EU) 2018/1673 of the European Parliament and of the Council of 23...
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27th Apr
Q&As
Section 30B of the Taxes Management Act 1970 (TMA 1970) permits HMRC, subject to various conditions, to amend a partnership’s tax return so as to...
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Produced in partnership with Denis Edwards of Normanton Chambers 26th Apr
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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20th Apr
Q&As
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...
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Produced in partnership with James Brockhurst of Gowling WLG 19th Apr
Practice notes
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...
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16th Apr
Practice notes
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...
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16th Apr
Practice notes
This Practice Note explains the special provisions that pertain to VAT in relation to costs that are the subject of either summary or detailed...
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15th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 (FB 2021) will, in relation to tax arrangements (within the meaning of the GAAR) entered into at any time...
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12th Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 (FB 2021) will, in relation to tax arrangements (within the meaning of the GAAR) entered into at any time...
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12th Apr
Precedents
Filed on behalf of the [insert party eg [Claimant OR Appellant] or [Defendant OR Respondents]]Number of witness statement: [insert eg first]Date:...
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12th Apr
Practice notes
Appeals and applications to the First-tier Tribunal and Upper Tribunal are both significantly affected by the coronavirus (COVID-19) pandemic. This...
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9th Apr
Practice notes
This Practice Note has been written by Anne Redston, Barrister. It is her personal view; she is not authorised to speak for the Tribunals Service or...
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Produced in partnership with Anne Redston 9th Apr
Practice notes
The Finance Act 2014 (FA 2014) introduced the concepts of an accelerated payment notice (APN) and a partner payment notice (PPN) to help combat tax...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 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 John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 9th Apr
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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9th Apr

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