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…

Guernsey Court Opens Door to Personal Liability for Trustees

The recent Guernsey decision in Investec Trust (Guernsey) Ltd & Bayeux Trustees Ltd v Glenalla Properties Ltd (2014) has far reaching consequences for Channel Island trustees administering foreign law trusts or entering into transactions not governed by the same law as their trust. As a matter of English law, trustees are personally liable to the…

Beneficiary Secures Victory in Concealed Denial of Trust Claim

A beneficiary recently succeeded in a claim for breach of trust against his grandfather who, having declared that he held the beneficiary’s share as sub-trustee, continued to act as if he had retained the beneficial interest. The significance of the decision in Sheffield v Sheffield and others [2013] EWHC 3927 (Ch) is likely to be confined…

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…