Trusts

Crucial CGT Relief Denied to Trustees

  A fairly clear lesson in the need to be conversant with the legislation and HMRC practice and to ensure that one’s ‘ducks are lined up’ before any major event or tax trigger point, despite several ingenious arguments in the…
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Holyrood approves Trusts & Succession Bill

Just before the festive season got fully underway, it is worth noting that on 20 December 2023, the devolved Scottish parliament voted unanimously to pass the Trusts and Succession (Scotland) Bill. Now expected to receive royal asset early in 2024,…
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Exemption for Small Trusts: Change is in the Air

What Changes are Coming?   Tax At Source & The Concession Six years ago there was a major shakeup in the taxation of interest and dividends – instead of tax at basic rate being deducted or deemed to have been…
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HMRC Unsuccessfully Challenges Tax Reducing Rectification

The England and Wales High Court (EWHC) has agreed to rectify two deeds of appointment made in 2013 that mistakenly terminated Nicholas Ware’s life interest, a qualifying pre-March 2006 life interest, in the assets of his late father, when they…
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Gift Ruled to be a Transfer of Beneficial Ownership

This is an interesting case for anyone involved in issues/disputes over legal and beneficial ownership.  It includes a useful review of relevant case law and clearly emphasises the importance of the circumstances and facts. The England and Wales High Court…
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Trust Registration Obligations: Update Early March 2020

  “The immanent extension of the online UK Trust Registration Service (TRS) to cover express trusts without any tax consequences, under the EU Fifth Anti-Money Laundering Directive (5AMLD), is likely to extend the number of registrable trusts from around 200,000…
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