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
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
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
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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22nd 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...
Read More >
22nd Jan
Practice notes
Significance of settlor’s domicile for offshore trustsThe extent of a trust’s liability to UK income tax and capital gains tax (CGT) depends on the...
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22nd 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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22nd Jan
Practice notes
This Practice Note considers shadow directors of offshore companies and the extent to which such directors may be subject to benefit in kind charges...
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Produced in partnership with Stephen Parnham 22nd 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 22nd Jan
Practice notes
This Practice Note is based on material provided by Tolley and Milestone International Tax Partners LLP, but is now maintained by PSL Private...
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22nd 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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22nd Jan
Practice notes
Capital payments made by an offshore trust to UK resident-domiciled beneficiaries are governed by a series of 'tax hierarchy' rules.The order in which...
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22nd Jan
Practice notes
FORTHCOMING CHANGE: As announced at Spring Budget 2020 on 11 March 2020, draft legislation relating to promoters and enablers of tax avoidance schemes...
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22nd Jan
Practice notes
Transfer of Assets Abroad CodeThe anti-avoidance provisions relating to a transfer of assets abroad are contained in Chapter 2, Part 13 of the Income...
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22nd Jan
Practice notes
This Practice Note considers the charging provision under section 727 of the Income Tax Act (ITA 2007) applicable to transferors of assets abroad who...
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22nd Jan
Practice notes
Under section 86 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992) where a UK resident and domiciled settlor has an 'interest' in a trust and...
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Produced in partnership with Tolley and Milestone International Tax Partners LLP 22nd Jan
Practice notes
Income, capital gains and offshore income gains (OIGs) of an offshore trust can all be deemed to accrue to a UK resident beneficiary who receives a...
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22nd 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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22nd Jan
Practice notes
Capital payments are generally taxed by matching them against available relevant income (ARI), offshore income gains (OIGs) and capital gains in that...
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22nd Jan
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
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
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 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

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