Blog
Rayner my parade! The importance of specialist advice.
Jemma Brimblecombe
10 November 2016
Absolute Discretion - the right to be unreasonable?
Many modern trusts are fully discretionary. The trustees might be empowered to apply the trust assets “...for such one or more of the beneficiaries, in such shares, at such ages, and on such trusts as my trustees shall, in their absolute and uncontrolled discretion, decide".
7 September 2016
HMRC publish details of new Worldwide Disclosure Facility
The Worldwide Disclosure Facility (WDF) opened on 5 September 2016 and gives people a final chance to come forward and clear up their tax affairs before HMRC begins to receive information under the OECD’s Common Reporting Standard (CRS) in 2017.
2 September 2016
Tax: a successful flip-flop
In this blog, we outline the tax implications of Bowring v HMRC, which concerned a scheme to reduce CGT on capital payments by a trust.
26 August 2016
The Great British tax off: how to bake a non-dom solution from HMRC’s latest ingredients
We recently outlined the proposed changes to the non-UK domicile (non-dom) tax regime following the publication on 19 August 2016 of HMRC’s latest consultation document. The consultation makes it clear that there will be a window of opportunity for individuals who will become deemed domiciled in April 2017 to plan for these changes, albeit a short one. We have outlined our initial thoughts on what the planning opportunities may be.
23 August 2016
Latest non-dom consultation – better late than never!
The latest round of consultation on the changes to be made to the non-dom tax regime was released on Friday. The changes are to come in on 6 April 2017 and will mean that non-doms are deemed to be UK domiciled for all tax purposes after 15 years of UK residence. There will also be look through provisions for UK residential property held in offshore structures.