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 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
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
The Foreign Account Tax Compliance Act (FATCA) has three core elements:•enhanced due diligence•broader information reporting, and•a potential...
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Produced in partnership with John Narducci (Partner) and Stephen C Lessard (Associate) of Orrick, Herrington & Sutcliffe LLP 8th Jan
Practice notes
FORTHCOMING CHANGE: Finance Bill 2021 will contain a number of measures, taking effect from Royal Assent, to strengthen the POTAS rules. These include...
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5th 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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24th Dec
Q&As
Under section 239 of the Finance Act 2004 (FA 2004), the scheme sanction charge is a charge to income tax which arises where, in any tax year, one or...
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7th Dec
Practice notes
Since 2007, HMRC has offered a series of disclosure facilities to individuals with offshore investments. These facilities provide a limited...
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29th Nov
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The Liechtenstein Disclosure Facility (LDF) was a voluntary disclosure facility...
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29th Nov
Practice notes
Following the closure of the Liechtenstein Disclosure Facility and the Crown Dependency Disclosure Facilities at the end of 2015 (see Practice Notes:...
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29th Nov
Q&As
Under the UK-US Agreement to improve International Tax Compliance and to Implement FATCA (the UK/US IGA) and the International Tax Compliance (United...
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29th Nov
Q&As
The Crown Dependencies of Jersey, Guernsey and the Isle of Man, and the Overseas Territories of Bermuda, Cayman Islands and British Virgin Islands...
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29th Nov
Practice notes
FORTHCOMING CHANGE relating to inaccuracy penalties: Following an initial discussion document that was published on 2 February 2015, HMRC is...
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29th Nov
Q&As
Rule 16(1) of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules 2009 (TP(FTT)(TC)R 2009), SI 2009/273, provides as follows (our...
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29th Nov
Q&As
In respect of an HMRC decision relating to direct tax, a taxpayer normally has 30 days to submit a written notice of appeal to HMRC (sections 30–31A...
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29th Nov
Q&As
In order to make an appeal, a taxpayer must first apply for permission to appeal (PTA). The PTA application should be submitted:•within 56 days of the...
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29th Nov
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
Q&As
HMRC can open an enquiry into a tax return by giving notice of an enquiry to the taxpayer (or their agent) within certain time limits (referred to as...
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29th Nov
Q&As
Although a First-tier Tax Tribunal (FTT) decision is binding on the parties to the particular case in respect of which the decision is made, it does...
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29th Nov

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