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.
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.
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…
Following a consultation this summer, draft legislation for inclusion in Finance Bill 2014 on the treatment of accumulated income and the alignment of payment and filing dates for trusts was published on 10 December 2013 for technical consultation. The Government has indicated it would welcome comments. If necessary they will review and amend that legislation…
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…
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…
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…
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…
The first filing date for properties within the charge at 1 April 2013 is 1 October 2013 and payment must be made by 31 October 2013. A snappy précis on Annual tax on enveloped dwellings (ATED) prepared by Farrer & Co.
HMRC’s consultation on reforming the periodic and exit charges on relevant property trusts, ended in mid-August. The reaction among professionals appears to have been somewhat chilly. HMRC’s stated aim is to triangulate a solution that simplifies the compliance burden while being revenue neutral on the Exchequer and that complies with the overarching policy of ‘fairness’;…
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