Trusts in commercial settings

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Practice notes
Plant and machinery allowances are the most widely used form of capital allowance. Plant and machinery is often (wrongly) interpreted as if the terms...
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Produced in partnership with Martin Wilson 12th 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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Produced in partnership with Martin Shah and Gary Barnett of Simmons & Simmons LLP 12th Jan
Practice notes
It is market practice for a tax covenant, also known as a tax deed, to form part of the transaction documents in respect of a sale of all the shares...
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9th Nov
Practice notes
This Practice Note describes the law and practice relating to elections under section 198 or 199 of the Capital Allowances Act 2001 (CAA 2001), which...
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Produced in partnership with Martin Wilson 12th Jan
Practice notes
Coronavirus (COVID-19): HMRC has stated in its International Manual that if a financial institution cannot meet the FATCA reporting deadline of 31 May...
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Produced in partnership with Ali Kazimi and Chris Orchard of Hansuke Consulting Limited 12th Jan
Practice notes
This Practice Note is about the meaning of a scheme of reconstruction for tax purposes.Tax neutrality is maintained where a company (company A) enters...
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9th Nov
Practice notes
This Practice Note explains:•what a determination in respect of direct tax (ie a direct tax determination) is•when HMRC might issue a direct tax...
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Produced in partnership with Philip Rutherford 12th Jan
Practice notes
Where a dispute is brought to an end by a payment of damages or compensation, whether under a court order or an out-of-court settlement agreement:•the...
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9th Nov
Practice notes
A damages or compensation payment may attract VAT. This depends on exactly what the payment is for. If it is purely compensatory, it will be outside...
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9th Nov
Practice notes
Overdrafts, term loans and revolving credit facilitiesThree common types of loan facility are:•overdrafts•term loans, and•revolving credit facilities...
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9th Nov
Practice notes
The Enterprise Investment Scheme (EIS) is designed to encourage investment in smaller, higher-risk trading companies by offering a range of tax...
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9th Nov
Practice notes
The regime for property authorised investment funds (PAIFs, or as HMRC use in regulations and their published guidance, Property AIFs)) was introduced...
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Produced in partnership with Martin Shah of Simmons & Simmons LLP based on material originally written by Charles Goddard of Rosetta Tax LLP 12th Jan
Practice notes
The value shifting rules are anti-avoidance provisions. They are similar to the rules applying to depreciatory transactions in that they target the...
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9th Nov
Precedents
1 Withholding and grossing up 1.1 All sums payable under this [Agreement] by or on behalf of any party (for the...
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9th Nov
Practice notes
A management buyout, or MBO, involves the acquisition of a business by its existing management team usually with the help of private equity financing....
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9th Nov
Practice notes
This Practice Note:•explains:◦the purpose of the tax indemnity clause that is normally found in a loan agreement, and◦that the standard drafting of...
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9th Nov

Most recent Trusts in commercial settings content

Practice notes
IntroductionMany trusts own shares as part of a portfolio of investments. This Practice Note looks at situations where trustees own shares in order to...
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Produced in partnership with Marilyn McKeever, Partner at New Quadrant Partners 20th Apr
Practice notes
Not all bond issues involve a trustee. It is up to the issuer to decide whether to appoint a trustee or a fiscal agent—see Practice Note: Transaction...
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19th Apr
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 Martin Blake of Farrer & Co 14th Apr
Practice notes
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESTrustees may be subject to personal liability if they commit a breach of trust...
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Produced in partnership with Elizabeth Haggis of Excuria Law 9th Apr
Practice notes
THIS PRACTICE NOTE APPLIES TO TRUST-BASED OCCUPATIONAL PENSION SCHEMESIndividual trustees v corporate trusteeThe most common trustee structures used...
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9th Apr
Practice notes
Overview of potential IHT chargesIt is important when establishing or operating an employee benefit trust (EBT) that the potential for Inheritance Tax...
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9th Apr
Practice notes
The EBT as a trustAn employee benefit trust (EBT) is a form of trust. A trust refers to the legal relationship created by a person, the settlor, when...
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Produced in partnership with Jeremy Glover of Fenwick Elliott 9th Apr
Practice notes
For general information on Guernsey, see Practice Note: Private Client jurisdictional guide—Guernsey.Guernsey as a trust jurisdictionWhilst there are...
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Produced in partnership with Gavin Ferguson of Ogier 9th Apr
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 9th Apr
Practice notes
This Practice Note was originally drafted by Christopher Kerr-Smiley, Legal Director at Womble Bond Dickinson, but is now maintained by Lexis®PSL...
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9th Apr
Practice notes
British Virgin Islands (BVI) trusts law is contained in the Trustee Ordinance, Cap 303 (as amended) as revised from time to time and the Virgin...
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Produced in partnership with Mourant Ozannes 9th Apr
Practice notes
For general information on the Isle of Man, see Practice Note: Private Client jurisdictional guide—Isle of Man.Legal frameworkIsle of Man trust law...
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Produced in partnership with Erin Trimble-Cregeen and Melissa Wong of Appleby (Isle of Man) LLC 9th Apr
Practice notes
This Practice Note was originally drafted by Owen Clutton of Macfarlanes LLP but is now maintained by Lexis®PSL Private Client.Trustee residence...
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9th Apr
Practice notes
The examples given in this Practice Note are based on a UK company that is privately owned but the same issues arise for families who own other types...
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Produced in partnership with Ken McCracken 9th Apr
Practice notes
For general information on Jersey, see Practice Note: Private Client jurisdictional guide—Jersey [Archived].Legal frameworkThe legal framework for...
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Produced in partnership with Mr David Dorgan 9th Apr
Practice notes
The use of special purpose vehicle structures is very common in aviation finance. They provide various advantages for lenders such as tax benefits and...
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Produced in partnership with Norton Rose Fulbright 8th Apr
Practice notes
This Practice Note considers what a purpose clause in a facility agreement actually is. It also explains what Quistclose trusts are, how they arise...
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8th Apr
Practice notes
What is a Quistclose trust?A Quistclose trust is an example of an ‘automatic’ resulting trust, ie a trust which arises where property is transferred...
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8th Apr
Practice notes
The security agentIn a syndicated loan transaction, the security agent (sometimes also known as the security trustee) (the Security Agent) will hold...
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8th Apr

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