Offshore anti-avoidance regimes

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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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19th May
Practice notes
Trustees—dutiesNature of dutiesThe difference between a duty and a power is:•the performance of a duty is obligatory•powers are to a greater or lesser...
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19th May
Practice notes
IHT—quick succession reliefQuick succession relief (QSR), which is not to be confused with taper relief, applies to a transfer of value which attracts...
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Produced in partnership with Katya Vagner of PwC 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
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...
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Produced in partnership with Mourant Ozannes and Carey Olsen 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
Practice notes
Beddoe applicationsWhen trustees are engaged in trust litigation, issues often arise as to how their litigation costs are to be funded. A Beddoe...
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Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside 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
Q&As
Can a life tenant in a Will bring a life interest to an end by choosing to end it themselves or does it only expire on death?Life tenantsA life...
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Produced in partnership with Lynne Counsell of 9 Stone Buildings 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
Trustees—self-dealing, unauthorised profits and conflicts of interestThe self-dealing ruleThe self-dealing rule is connected to, but distinct from,...
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19th May
Practice notes
Cayman Islands STAR trusts—common usesThis Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman...
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Produced in partnership with Mourant Ozannes and Carey Olsen 19th May

Most recent Offshore anti-avoidance regimes content

Practice notes
IHT—anti-avoidance provisionsSTOP PRESS relating to Finance Act 2021: Finance Act 2021 (FA 2021) contains a number of measures, taking effect from...
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23rd Jul
Practice notes
What is transfer pricing?Transfer pricing is a concept that refers to the pricing of goods, services, funds and tangible and intangible assets...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 21st Jul
Practice notes
Tax consequences for close companiesSummary of tax considerationsThe concept of a close company is intended to capture those companies that are...
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15th 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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1st Jul
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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30th Jun
Practice notes
When do the UK transfer pricing rules apply?IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation...
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Produced in partnership with Simon Gough and Caroline Brown of Bird & Bird LLP 23rd Jun
Practice notes
Disguised remuneration—structure of the regime and its implications in practiceIntroductionHMRC has, for many years, sought to ensure that the rewards...
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Produced in partnership with Karen Cooper of Cooper Cavendish 23rd Jun
Practice notes
Disguised remuneration and the self-employedCoronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary...
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Produced in partnership with Karen Cooper of Cooper Cavendish 7th Jun
Q&As
Coronavirus (COVID-19)—what is the potential impact on transfer pricing?There are a range of issues that could arise for transfer pricing purposes,...
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Produced in partnership with Kapisha Vyas of Simmons & Simmons and Tomoko Ikawa of Simmons & Simmons 6th Jun
Q&As
Are there any disguised remuneration consequences of leaving shares to an employee under a Will?This Q&A considers whether the provisions set out in...
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Produced in partnership with Christopher Snell of New Square Chambers 6th Jun
Q&As
A non-resident trustee disposes of a UK residential property in the tax year 2017/18. The trust was settled by a UK domiciled settlor in 2002. How...
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5th Jun
Practice notes
Transfer of assets abroad—transferors having the power to enjoy incomeThis Practice Note considers the charge to of 'transferors' under the transfer...
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5th Jun
Practice notes
Transfer of Assets Abroad—EU DefenceTransfer of Assets Abroad CodePart 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains a key UK...
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Produced in partnership with James Quarmby of Stephenson Harwood 5th Jun
Practice notes
Transfer of assets abroad code—motive defencePart 13, Chapter 2 of the Income Tax Act 2007 (ITA 2007) contains key UK anti-avoidance provisions known...
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Produced in partnership with James Quarmby of Stephenson Harwood 5th Jun
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 5th Jun
Practice notes
Offshore trusts—attribution of gains to settlors—tainting of protected settlements and grandchildren settlementsUnder section 86 of the Taxation of...
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5th Jun
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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5th Jun
Practice notes
IHT—deduction of liabilitiesFORTHCOMING CHANGE: As announced at Budget 2018, draft legislation to be included in Finance Bill 2019–20 was published on...
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5th Jun

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