Wills & Trusts Law Reports | Autumn 2017 #169The appeal concerned a tax avoidance scheme by which employers paid remuneration to their employees through an employees’ remuneration trust in the hope that the scheme would avoid liability to income tax and Class 1 national insurance contributions. The question on appeal was whether an employee’s remuneration was taxable as their emoluments or earnings when it was paid to a third party in circumstances in which the employee had no prior entitlement to receive it himself or herself.
The employing companies, including RFC, operated the tax avoidance scheme in the tax years between...
Sadiya Choudhury reviews a case considering the IHT consequences of the transfer of a reversionary interest to an offshore settlement ‘This decision is one of the few examples in which the tribunal or the courts have applied the principles of anti-avoidance as developed in the case law in an IHT context.’In Michael Lawton Salinger and …
Continue reading "IHT: Out of step"
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A recent case highlights the importance of meticulous implementation when tax planning. Emma Pearce explains ‘WT Ramsay v IRC [1981] was the leading authority on the approach to statutory interpretation adopted by courts to counter tax avoidance schemes.’ This article discusses the First-tier Tribunal’s (FTT) decision in Trustees of the Morrison 2002 Maintenance Trust v …
Continue reading "Tax Planning: The gain plan"
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