Tax avoidance, evasion and non-compliance

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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
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

Most recent Tax avoidance, evasion and non-compliance content

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 Forsters LLP 21st Jan
Practice notes
Transfer of Assets Abroad CodePart 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains a key UK anti-avoidance mechanism known as the...
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Produced in partnership with James Quarmby of Stephenson Harwood 21st Jan
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 Leon Kazakos QC of 2 Hare Court 19th Jan
Practice notes
Part 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains key UK anti-avoidance provisions known as the transfer of assets abroad code (TAA...
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Produced in partnership with James Quarmby of Stephenson Harwood 19th Jan
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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18th Jan
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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18th Jan
Practice notes
Corporate transparency is now viewed as an essential element in any strategy aimed at reducing or eliminating corruption, tax evasion, terrorist...
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18th Jan
Practice notes
Effective preparation of bundles is an essential element of a smooth, orderly hearing and something which practitioners should keep in clear focus as...
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Produced in partnership with Ross McLeod, Christopher Humby, Leo Kitchen and Damian Curran of Quinn Emanuel Urquhart & Sullivan UK LLP 18th Jan
Practice notes
Brexit: As of exit day (31 January 2020), the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has...
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17th Jan
Practice notes
What are cryptoassets?One of the hurdles in relation to understanding non-traditional currencies and assets lies in the inconsistent use of language....
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17th Jan
Practice notes
The trustee borrowing rules were introduced in 2000 to counter a specific planning scheme known as a 'flip-flop'. The scheme allowed the settlor of an...
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Produced in partnership with Dhana Sabanathan, Partner of Winckworth Sherwood LLP 15th Jan
Practice notes
Major changes to the taxation of offshore trusts were introduced in 2017 and 2018. These changes are summarised in Practice Note: Changes to the...
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15th Jan
Practice notes
This Practice Note considers the application of the Foreign Account Tax Compliance Act (FATCA) to UK Trusts, as implemented in the UK by the...
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Produced in partnership with Jason Collins and Catherine Robins of Pinsent Masons 15th Jan
Practice notes
This Practice Note considers the provisions of part 5, sections 619–648 of the Income Tax (Trading and Other Income) Act 2005 (ITTOIA 2005) (Ch 5)...
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15th Jan
Practice notes
When is Sch 4C in point?A Sch 4C pool, ie a pool of gains to which Schedule 4C to the Taxation of Chargeable Gains Act 1992 (TCGA 1992) applies, is...
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15th Jan
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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15th Jan
Practice notes
This Practice Note provides an introduction to the Foreign Account Tax Compliance Act (FATCA) for private client practitioners and contains links to...
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15th Jan
Practice notes
FORTHCOMING CHANGE: Section 36 of Finance Bill 2019–21 sets out draft changes to the calculation of top-slicing relief such that a taxpayer’s personal...
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Produced in partnership with Simon Gorbutt 15th Jan
Practice notes
As discussed in the UK resident non-domiciliaries—tax planning Practice Note, non-domiciled individuals resident in the UK can claim to be taxed on...
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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.In October 2013, the Isle of Man, Jersey and Guernsey each signed...
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15th Jan

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