The acquisition of domicile of choice: HMRC's changing approach
There has been another success for HMRC at the First-tier Tax Tribunal in relation to a taxpayer’s domicile st...
Inheritance tax and trusts
Inheritance tax and trusts
Inheritance tax: the nuances of ‘interest in possession’
Before the sudden reforms of the inheritance tax rules in March 2006, there was a fundamental distinction betw...
FOTRA securities: a question of residence for inheritance tax
There are not very many tools in the inheritance tax planning toolbox.
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Implied trusts and beneficial ownership: who is the real owner?
© Getty images/iStockphoto ‘Taxation of income is based on beneficial ownership, not legal ownership. ...
The practical challenges of identifying the right sort of trust
Testators have a range of possible trusts that can be used for partners, young children and grandchildren in t...
Inheritance tax: choosing the right sort of trust to provide for partners, children and minors
Types of will trust Even after the changes to the inheritance tax treatment of trusts that were made in March...
The rules of domicile: what issues can impact an individual’s tax status?
The concept of domicile links an individual to a particular jurisdiction.
The concept of 'connected persons': what are the ties that bind?
The concept of connected persons appears throughout the direct taxes legislation.
Grappling with the anomalies of inheritance tax penalties
Recently, there has been much litigation about the procedural aspects of the tax code, including several decis...
Is there a place for multiple trusts?
In the January 2022 issue of Tax Adviser, we examined the changes that had been made to trusts from 18 Novembe...