The upper tribunal (UT) has turned down HMRC’s appeal in Vigne against the First-tier Tribunal (FTT) decision that “DIY-Plus” livery services provided to clients who stabled their horses with the late Mrs. Vigne were enough for inheritance tax (IHT) business property relief...
Less than a week to go before the Requirement to Correct (RTC) deadline of 30 September 2018 elapses. RTC requires taxpayers to make a disclosure of any undeclared tax (Income Tax, Capital Gains Tax and Inheritance Tax) arising before the...
The UK Government has introduced a raft of legislation to address tax evasion and latterly tax avoidance. This has included; The Requirement to Correct legislation which has introduced punitive offshore penalties and extended assessing time limits for Income Tax, Inheritance...
The Chancellor announced in his 2017 Autumn Budget that the Government will publish a consultation in 2018 on how to make the taxation of trusts “simpler, fairer and more transparent”. This won’t be the first time that the Government has...
Recent changes in the domicile rules affecting an individual’s inheritance tax (IHT) non-domicile status can have serious effects on trusts they have set up. Overseas assets settled on trust when the settlor was non-domiciled are excluded property for IHT purposes...
We now know that inheritance tax benefits previously associated with the use of corporate structures to hold UK residential property will be removed with effect from 6 April 2017. The new rules treat the interest in the holding entity as...
Power Adhesives Ltd. almost came unstuck when, under the guidance of their advisers, the Company adopted an inappropriate arrangement to remove the possible problem of having to repay a director’s loan account on death. The arrangement made, for non-tax reasons,...
A company almost came unstuck when, under the guidance of their advisers, the Company adopted an inappropriate arrangement to remove the possible problem of having to repay a director’s loan account on death. The arrangement made, for non-tax reasons, would...
It is said that the real sign that a ship is in trouble is not when the rats jump overboard but when the officers abandon it mid-voyage. If that’s the case, HMRC appears to be sinking because a number of...
Finance Act 1986 (FA 1986) s 102 treats property that an individual has given away as remaining in the donor’s estate for IHT purposes if · (s 102 (1)(a)) possession and enjoyment of the property is not bona fide assumed...
Here we summarise some of the less prominent draft clauses for the 2016 finance Bill. These may have been announced before or represent little change in practice but they are all important because they all affect someone. Capital Gains Tax: disposals...
Reduction of pensions lifetime allowance As announced in the March Budget the lifetime allowance (LTA) will be reduced from £1.25m to £1m, with effect from 6 April 2016. Protection arrangements will apply. The LTA will be indexed in line with...
Following lots of discussion and debate in recent years regarding the reform of inheritance tax (IHT), only a couple of minor points arose in the autumn statement. First, following a number of changes over recent years extending the exemption from...
On 16 July 2015 HMRC published draft Regulations containing the proposed IHT hallmarks for DOTAS ( Disclosure of Tax Avoidance Schemes) purposes. These have attracted attention and criticism because of the breadth of their potential application. Consequences of arrangements being...
From 5 April 2017 there will be a new £175,000 allowance on homes left to children and grandchildren. At the same time the Chancellor confirmed that the current nil rate band of £325,000 will be fixed until 2020/21. Both allowances...
The pre-owned assets tax (POAT) was ten years old on 6 April 2015 but no party was held because nobody would have attended. Introduced as a countermeasure against inheritance tax avoidance schemes, POAT applies to anyone who disposed of an...
Despite all the media hype around Inheritance tax and thresholds, there were no NEW announcements regarding Inheritance tax or were there? There was a cryptic comment in the Budget speech regarding restricting the use of deeds of variation as if these...
The Taxation of Pensions Bill 2014 (TPB) will enact the tax changes enabling flexibility of pension draw-down. Changes were announced to the tax treatment of funds remaining in a personal pension scheme on the death of the member. Under current...
The case of Routier and Venables v HMRC concerned a bequest to charity under the will of C and possible relief from inheritance tax (IHT) under IHTA 1984 s 23. (more…)
The Confederation Fiscale Europeenne (CFE) (a pan European body representing tax professionals) has published examples of specific examples of cross-border IHT problems encountered by its members. (more…)
The proposals to simplify trust exit and ten-year anniversary (TYA) charges, due to come into effect on 6 April 2015 have been modified in the consultation document Inheritance tax: A fairer way of calculating trust charges issued by HMRC on...
The new Inheritance and Trustees’ Powers Act 2014 (ITPA 2014), due to come into force on 1 October 2014 includes changes affecting how: intestate estates are distributed; and trustees can distribute income and capital to beneficiaries These changes apply to...
The major part of the reform of IHT on trusts concerns the ten year charge (formally the “principal charge”) on trusts. However, proposals made in the 2013 Budget would have meant that no matter how many trusts a settlor might...
Individuals who have established trusts need to be aware of forthcoming changes to their tax treatment, due in April 2015. Those looking to use trusts as part of a wealth management/succession plan will need to consider whether the use of...
The first phase of the changes aimed to simplify the way in which inheritance tax (‘IHT’) is charged on trusts will be introduced from April. Their stated intention is to be tax neutral but they look likely to increase trusts’...
Best (Buller’s executor) v RCC (UKFTT 03217) follows the example set in HMRC v Lockyer, executor of Pawson in refusing BPR on a property letting business. Best differs from Lockyer in facts but not in principle. The differences are that:...
The professional bodies have issued a technical release on the availability of BPR in two situations. Firstly, where shares in unquoted trading companies are held by partnerships or LLPs. Secondly, where surplus cash is held by businesses and companies, which...
HMRC has designated the market operated by The Channel Islands Securities Exchange Authority Limited as a recognised stock exchange under Section 1005 (1) (b) Income Tax Act 2007 with effect from 20 December 2013. Therefore as from 20 December 2013...
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