Un-Tainting Protected Settlements – A Cure When Prevention Fails?

Important changes were made to the UK’s deemed domicile regime in 2017 which are now a significant area of risk for offshore trustees with UK resident settlors.

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Chancellor Widens ATED Tax Net in Budget 2014

The Chancellor in his 2014 Budget has announced an extension of the Annual Tax on Enveloped Dwellings (“ATED”). ATED imposes an annual tax charge on residential property worth £2m or more held within corporates. The Chancellor has announced the charge is to be extended to a broader range of residential property, so that as of…

Chancellor Cuts PPR Relief Period in Autumn Statement

While measures designed to ensure non-UK residents paid CGT on the sale of residential property were widely trailed in the media prior to today’s Autumn Statement, another measure that will affect many vendors also slipped by relatively unnoticed. Today the Chancellor announced HM Government’s intention to cut in half the final period exemption for Principal…

Jersey Revives Rule in Re Hastings Bass

An amendment to Jersey’s trust law came into force on Friday 25th October 2013 to incorporate what has become known as the rule in Hastings-Bass into statute. The rule, which has emerged from nearly 40 years of case law, has traditionally allowed trustees who have made a mistake as to their dispositive powers to apply…

Executors Lose BPR Appeal on Furnished Holiday Lets

The Court of Appeal has rejected, for the final time, the executors of Nicolette Pawson application for leave to appeal the Upper Tribunal‘s decision in HMRC v Pawson (deceased) [2013] UKUT 050 (TCC) that a let holiday cottage was held mainly as an investment and so did not qualify for business property relief (BPR) for…

Marriage Transferable Tax Allowance – The Basics

The Government has recently announced that from April 2015 some married couples (including same and opposite sex) and civil partners will be eligible for a new Transferable Tax Allowance (TTA) for income tax:  What We Know Thus Far The TTA for married couples will enable spouses and civil partners to transfer a fixed amount of…