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…

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…

My first post

Welcome to my new blog. I’ve never blogged before, partly owing to ignorance as to how to go about it and partly to doubts as to whether anyone would read it. Ignorance remedied and doubts notwithstanding, I’m taking the plunge. The focus of this blog will be topics that (eventually) affect us all – growing…