Wills & Trusts Law Reports | December 2015 #155On 21 June 2001 the settlor, who was then non-domiciled in the UK, settled cash derived from a Jersey bank account on the trusts of a Jersey-resident discretionary trust called the Michael Dreelan Trust (MDT). The settlor became deemed domiciled in the UK for inheritance tax purposes from the beginning of the tax year 2003/04. Subsequently, on 4 April 2008, the settlor and others set up another settlement called the Dreelan Brothers Joint Trust (DBJT) and 25,000 ordinary shares in Qserv Limited were transferred from the MDT. These were later sold for cash that was UK situs property. On 2...
Anna Moore sets out the next stage in the simplification of trust tax charges ‘HMRC have confirmed that they are “committed to ensuring fairness in the tax system and reducing undue burdens on trustees and their advisers”.’ In December 2013, HM Revenue & Customs (HMRC) published a summary of the responses received to their second …
Continue reading "IHT: Managing your exit"
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Anna Moore discusses the pros and cons of the recent HMRC consultation paper on the simplification of tax for trusts ‘It is clear that trusts where the settlor has relatively straightforward arrangements are more likely to benefit from the changes and that the calculation in relation to older trusts or more complicated arrangements is more …
Continue reading "Trusts: ‘Relaxing’ the HMRC way"
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Imogen Buchan-Smith sets out the key points of the much-anticipated GAAR ‘While the GAAR’s purpose is “the counteraction of tax advantages arising from tax arrangements that are abusive”, and the taxes included within its scope are clear, the actual arrangements that the government intends will fall within its ambit may be less so.’The introduction of …
Continue reading "Tax Planning: Curtailing abuse"
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