General principles of tax avoidance

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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
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
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 General principles of tax avoidance content

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
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
The general anti-abuse rule (the GAAR):•counteracts (by the making of adjustments on a just and reasonable basis by HMRC or the taxpayer)•tax...
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9th Apr
Practice notes
FORTHCOMING CHANGE: Finance Act 2021 will, with effect from Royal Assent, reduce the maximum level of a standard follower notice penalty to 30% (down...
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Produced in partnership with Keith Gordon of Temple Tax Chambers 6th Apr
Practice notes
Lexis®PSL Tax is grateful to Nigel Doran of Macfarlanes LLP for his comments on an earlier draft of this Practice Note. However, the views expressed...
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1st Apr
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021, published on 11 March 2021, contains a number of measures, taking effect from Royal Assent, to take further...
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26th Mar
Practice notes
The Scottish general anti-avoidance rule (Scottish GAAR) aims to protect revenue through counteracting tax avoidance arrangements, and is intended to...
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Produced in partnership with Andrew Ford of Barr & Ford Limited 9th Mar
Q&As
The Ramsay principle is an approach to statutory interpretation that has been developed by the courts in cases involving tax avoidance. For a general...
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29th Nov

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