Lynnette Bober National Tax Consultant at Smith & Williamson discusses offshore trust issues arising from the Finance Act 2008 changes
The Finance Act 2008 Sch 7 overhauled the remittance basis of taxation and extended the CGT non-UK-resident trust anti-avoidance legislation such that foreign domiciliaries can now potentially be subject to CGT under the beneficiary charge provisions. This article focuses on the main issues relevant to non-UK-resident trusts with particular focus on the changes to the CGT anti-avoidance provisions.
General Considerations
There are general issues for trustees to consider such as whether the Income Tax Act 2007 s 809M(2)(g) 'relevant person' definition applies to their relationship with the settlor. If s...
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Lynnette Bober National Tax Consultant at Smith & Williamson discusses offshore trust issues arising from the Finance Act 2008 changes
The Finance Act 2008 Sch 7 overhauled the remittance basis of taxation and extended the CGT non-UK-resident trust anti-avoidance legislation such that foreign domiciliaries can now potentially be subject to CGT under the beneficiary charge provisions. This article focuses on the main issues relevant to non-UK-resident trusts with particular focus on the changes to the CGT anti-avoidance provisions.
General Considerations
There are general issues for trustees to consider such as whether the Income Tax Act 2007 s 809M(2)(g) 'relevant person' definition applies to their relationship with the settlor. If s...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
