The current state of play with HMRC v Murray Group Holdings has lessons for lax trustees. Catharine Bell and Nicole Aubin-Parvu provide an update ‘HMRC argued that where an employee was given practical access to or control of monies it mattered not that he did not have absolute legal title to them.’The unsuccessful appeal by …
Continue reading "Trust Management: Extra time and possible penalties?"
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Katie Hawksley finds that Rogge v HMRCC summarises how the settlor-interested rules work in the UK and offshore ‘The judgment touched on the interaction between a settlor’s liability to income tax and that of the trustees (and the complications which can arise as a result), raising some interesting points for private client practitioners to bear …
Continue reading "Tax: Justice and reason?"
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Wills & Trusts Law Reports | April 2012 #118There were three joined appeals, namely that of R who had paid interest under a loan to the trustees of a trust of which he was the settlor and those of K and the trustees of a trust in which K, the settlor, was interested. K had paid rent to the trustees of a trust under which he was a settlor and of which he was the life tenant. All appealed income tax assessments on the basis that it is impossible for a taxpayer to be taxed on his own expense. Parliament could not have intended s660A(1) of the Income and Corporation Taxes Act 1988 to have this effect. Section 660...
