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.
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…
Next Steps in Reforming IHT Periodic Charges for Relevent Property Trusts
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…
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…
‘Squaring the Triangle’: Simplifying IHT charges on relevant property trusts
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’;…
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…
TopTrustNerdery 