The government has accepted many, but not all, of recommendations made by the House of Lords Economic Affairs Committee in its recent review on additional HMRC powers. HMRC accepts STEP’s interpretation that the inheritance tax spouse exemption could be available for assets held in a trust where the settlor has reserved a benefit. An opinion of the GAAR advisory panel on loan to participator schemes serves as a cautionary tale for taxpayers seeking to avoid tax charges through contrived arrangements. In Quentin Skinner 2005 Settlement, the Upper Tribunal denied entrepreneurs’ relief to individuals with interests in possession in trusts holding shares in the family business for around four months before the trustees’ disposal of those shares.
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The government has accepted many, but not all, of recommendations made by the House of Lords Economic Affairs Committee in its recent review on additional HMRC powers. HMRC accepts STEP’s interpretation that the inheritance tax spouse exemption could be available for assets held in a trust where the settlor has reserved a benefit. An opinion of the GAAR advisory panel on loan to participator schemes serves as a cautionary tale for taxpayers seeking to avoid tax charges through contrived arrangements. In Quentin Skinner 2005 Settlement, the Upper Tribunal denied entrepreneurs’ relief to individuals with interests in possession in trusts holding shares in the family business for around four months before the trustees’ disposal of those shares.
If you are not a subscriber, subscribe now to read this content.
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