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 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 Tax avoidance, evasion and non-compliance content

Practice notes
AAdministrationThe process starting on the date of the deceased's death and ending on the date the deceased's affairs are finalised by his personal...
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15th Jan
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.On 6 October 2011, the governments of Switzerland and the UK signed an agreement...
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15th Jan
Practice notes
STOP PRESS: The All-Party Parliamentary Group on Anti-Corruption & Responsible Tax, which was established in June 2020 is currently researching more...
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15th Jan
Practice notes
When looking at the definition of chargeable transfers and transfers of value in the Inheritance Tax Act 1984 (IHTA 1984), it is perhaps not...
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Produced in partnership with Katya Vagner of PwC 15th Jan
Practice notes
FORTHCOMING CHANGE: As announced at Spring Budget 2020, Finance Bill 2020–21 will include provisions to strengthen anti-avoidance rules, including the...
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15th Jan
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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Produced in partnership with Alison Cartin of Bryan Cave Leighton Paisner 15th Jan
Practice notes
The Offshore bonds and other foreign policies Practice Note discusses what is meant by an offshore bond and a foreign policy and it explains the tax...
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Produced in partnership with Simon Gorbutt 15th Jan
Practice notes
This Practice Note considers the charging provisions on individuals under section 731 of the Income Tax Act 2007 (ITA 2007), also known as ‘the...
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15th Jan
Practice notes
FORTHCOMING CHANGE: As announced at Spring Budget 2020 on 11 March 2020, the government is taking forward further measures to reduce the scope for...
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15th Jan
Practice notes
This Practice Note considers:•requirement to correct and failure to correct penalties•penalties for offshore matters or offshore transfers•offshore...
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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 Organisation for Economic Co-operation and Development (OECD)’s Multilateral Convention on Mutual...
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15th Jan
Practice notes
What is the requirement to correct?The legislation for the requirement to correct (RTC) regime is set out in section 67 and Schedule 18 to the Finance...
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15th Jan
Practice notes
This Practice Note considers the charge to of 'transferors' under the transfer of assets abroad code (TAA Code) where income of a person abroad is...
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15th 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 Simon Gough and Caroline Brown of Bird & Bird LLP 15th Jan
Practice notes
Coronavirus (COVID-19): in light of the coronavirus crisis, the government has announced temporary measures to support the self-employed. For more...
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Produced in partnership with Karen Cooper of Cooper Cavendish 15th Jan
Practice notes
Direct recovery of tax debts (DRD) refers to HMRC's ability to instruct banks and building societies (ie deposit-takers) to deduct amounts to settle...
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15th Jan
Practice notes
Coronavirus (COVID-19): During the coronavirus pandemic, HMRC allowed deferral of certain VAT payments and self-assessment payments on account (for...
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15th Jan
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 15th Jan
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 will introduce a new information notice that HMRC may issue to anyone it suspects of being involved in the...
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15th 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...
Read More >
15th Jan

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