Charitable giving and tax: dispelling the myths
Only a quarter (26%) of high net worth individuals (HNWIs) say that an adviser has raised the topic of charitable giving with them in the past, yet two in five believe it is important to discu
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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 status (Shah v HMRC [2023] UK FTT 539 (TC)).
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 between life-interest trusts and discretionary trusts.
Implied trusts and beneficial ownership: who is the real owner?
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‘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 their wills, including an immediate post-death interest, trusts for bereaved minors, and
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 2006, testators have a range of possible trusts that can be used for partners
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 decisions of the Supreme Court on the Taxes Management Act 1970 alone.