This week’s edition of Private Client highlights includes: (1) the Court of Protection directs the Office of the Public Guardian to cancel three LPA registrations on the grounds of defective execution and lack of competence of the certificate provider (Re AR); (2) two Court of Protection decisions on deprivation of liberty which applied the multifactorial approach set out in the Supreme Court AGNI judgment; (3) HMRC’s new compliance-check factsheet (CC/FS91) on penalties and criminal offences in respect of the promotion of certain tax avoidance arrangements; (4) the Information Commissioner’s Office confirms its transition to the Information Commission under the Data (Use and Access) Act 2025, and (5) the IRS announces its partnership with HMRC’s whistleblower program.

This week’s edition of Private Client highlights includes: (1) HMRC publishes guidance on new IHT relief caps for agricultural and business property and releases an apportionment tool for advisers and personal representatives; (2) several updates to HMRC Manuals to reflect changes introduced by Finance Act 2026 effective from 6 April 2026; (3) the FTT imposes maximum DOTAS penalty on scheme promoter in liquidation in Revenue and Customs Commissioners v Tailored UK Services Ltd (in liquidation)); (4) the FTT dismisses appeals against CGT liabilities on UK-situs loan notes but cancels penalties in The Personal Representatives of Mukesh Sehgal and another v Revenue and Customs Commissioners); (5) HMRC publishes helpsheet HS266 for FIG relief claimants; and (6) the Court of Appeal’s decision in Mazur v Charles Russell Speechlys LLP which confirms that non-authorised persons can conduct litigation under supervision.

This week’s edition of Private Client highlights includes: (1) the Ministry of Justice’s new factsheet on applying for payment out of a fund following the death of a Court of Protection client; (2) JTC Employer Solutions Trustee v Garnett, in which the High Court permitted rescission of sub-trust appointments saving IHT for EBTs caught by income tax avoidance rules; (3) the Charity Commission’s consultation on the vulnerability of non-profit organisations to terrorist financing abuse; (4) the Public Bill Committee stage of the Finance Bill 2025 begins on 28 January; (5) NHS Mid & South Essex ICB and Ors v HMRC, an FTT decision which considered the meaning of interest with respect to redress payments, and (6) changes to Switzerland’s international succession law allowing choice of jurisdiction in force from 1 January.

This week’s edition of Private Client highlights includes: (1) Trust registration service—HMRC publishes guidance on registration and CIOT flags issue with changing details of lead trustee; (2) the FTT reduces IHT liability on EBT sub-trust valuation in McIlhone v Revenue and Customs Commissioners; (3) the Supreme Court rules on ‘significant influence’ under the salaried members provisions in HMRC v BlueCrest Capital Management (UK) LLP; (4) HMRC consults on introducing a criminal offence for reckless untrue statements in direct tax; (5) lawyers to face fit and proper tests under the Financial Conduct Authority’s AML regime; and (6) the CLLS and Law Society respond to the DBT’s UK corporate re-domiciliation consultation.

This week’s edition of Private Client highlights includes: (1) Application to Withhold Closed Material: Concurrent Civil Proceedings, in which the Court of Protection approved an application to withhold ‘closed material’ from P’s parents in order to progress a capacity assessment of P; (2) John Tenconi v HMRC, which held that the transfer of company distribution rights was a disposal for CGT; (3) Krishnamohan v Revenue and Customs Commissioners, where the FTT held that certain transactions were not option grants chargeable to CGT; (4) Upham v HSBC, in which the High Court rejected a compensation claim brought by Eclipse film scheme investors against the bank which devised the scheme, and (5) In Re Estate of Constantin Mattas, in which the Royal Court of Jersey rescued a charitable trust mixed with a private purpose.

This week’s edition of Private Client highlights includes: (1) analysis of In the Estate of Kathleen Coady, a decision on whether a Will signed under coronavirus (COVID-19) restrictions was valid; (2) Ivey v Lythgoe, a contentious probate case in which the court ordered compulsory mediation; (3) National Iranian Oil Company v Crescent Gas Corp Ltd, where the court held that a declaration of trust signed by an agent did not defeat a claim for a transaction at undervalue; (4) publication of an updated version of the Professional Conduct in Relation to Taxation; (5) Armstrong v Armstrong, which concerned satisfaction of the equity arising from proprietary estoppel, with an alternative award under the Inheritance (Provision for Family and Dependants) Act 1975, and (6) analysis of Aubrey Weis v HMRC, in which the High Court permitted the taxpayer to bring a judicial review claim against HMRC in respect of his historical domicile status.

Private Client analysis: The case of Marcus v Marcus concerned a discretionary trust created in favour of the settlor’s ‘children and remoter issue’. The settlor died believing he had two biological children (who would, therefore, be the beneficiaries). However, the court found that, on the balance of probabilities, one child was not the biological child of the settlor, and instead was a stepchild. The issue that arose, then, was whether this stepchild could qualify, for the purpose of the trust, as a child of the settlor and therefore fall within the beneficial class. The court found, applying trust construction principles (and acknowledging the stark inequality that would arise otherwise), that the stepchild was included in the definition of ‘children’ and therefore entitled to benefit from the trust assets. Written by Adam Carvalho, legal director and Olivia Shorrock, solicitor of Myerson.

Private Client analysis: The court rejected a claim brought by a disappointed family member of a deceased relative that the said relative had intended to create a secret trust in respect of valuable jewellery that formed part of the deceased’s estate. Similarly, the court rejected the contention that the sole beneficiary of the Will (a non-family member) was estopped from denying the family member’s right to the jewellery. The decision contains a useful summary of the elements necessary to establish a secret trust; discussion of the burden of proof; and a reminder of how important it is to plead a case with particularity when making such allegations. Written by Christopher Snell, barrister, at New Square Chambers.

This Practice Note is a horizon scanner tracking key future developments in Private Client. It provides details of key dates for your diary (including forecasted dates where the actual date is unknown) and relevant commentary in relation to: • Legislation: ◦ Bills in progress ◦ Acts not in force, partially in force or subject to staged introduction ◦ Statutory Instruments in progress, partially in force or subject to staged introduction • Other key developments, such as: ◦ Case appeals ◦ Consultations ◦ Calls for evidence ◦ Inquiries This horizon scanner does not cover past developments, such as legislation fully in force. To view developments in force, see Practice Note: Private client—key developments tracker. Legislation Bills in progress What’s happening? When? What’s the impact? Find out more Acts not in force, partially in force or subject to staged introduction What’s happening? When? What’s the impact? Find out more Modernising Lasting Powers of Attorney Unknown The Powers of Attorney Act 2023 received Royal

This new starter guide provides an introduction to the Private Client practice area. It is aimed at trainee solicitors, paralegals and those who are new to Private Client work. It focuses on key topics in Private Client law, and includes links to other Lexis+® UK resources and materials which provide more comprehensive information. Those who are new to Private Client are also likely to find the Overviews in each of the subtopics in the Private Client module useful. These Overviews give an introduction to each of the subtopics in the Private Client module with links to relevant content within the subtopic to help navigate the area concerned. For example, see: Will drafting—overview and Inheritance tax (IHT)—overview. Where something is not covered in this guide, try browsing our Private Client topic tree or using the search bar to find further Private Client content. This guide also contains links to help you make the most of the Private Client materials, including how to sign up for email alerts and contact the LexisAsk team. Key topics in Private Client The

Private Client analysis: Finance (No 2) Bill 2024–26 (F(No 2)B 2024–26), also known as Finance Bill 2026 and to be enacted as Finance Act 2026, was published on 4 December 2025.

The following Private Client resources, providing useful practical commentary, legislation, rules and guidance for Private Client lawyers, whether in private practice or in-house, are available in Lexis+® UK. They are referenced and linked to in the Private Client content in Lexis+® UK. Please note, however, the titles listed can only be accessed with the relevant Lexis+® UK subscription(s). Wills, probate and trusts Title Summary Who should use this resource? Williams on Wills The leading commentary on all aspects of the law of Wills. Lawyers or other professionals involved in the drafting or interpretation of Wills. Tristram and Coote's Probate Practice The leading commentary on probate, providing up-to-date, expert guidance on all aspects of probate procedure and including precedents recommended by Probate Registrars. Lawyers or other professionals involved in probate or estate administration work, including contentious probate. Butterworths Wills Probate and Administration Service A comprehensive service containing clear, step-by-step guidance on all areas of the law and practice of probate and estate administration, from planning and drafting a Will, through administration of the estate and