Simon Rylatt and Jenny Wilson-Smith (Boodle Hatfield) answer a query on the operation of the revised draft FB rules on non-doms and offshore trusts.
Sara Cohen (Lewis Silkin) answers a query on the capital treatment on any gain during a staged buyback of shares.
Shiv Mahalingham (Duff & Phelps) answers a query on designing a compliant transfer pricing structure which is efficient from a tax arbitrage perspective.
Jackie Wheaton (Moore Stephens) answers a query on the tax treatments of option contracts for income taxpayers and corporation taxpayers.
Adam Carvalho (Farrer & Co) sets out the options open to trustees when a trustee executes a document that has an unintended effect, and the current requirements for applying to court for a remedy.
Ceinwen Rees and Richard Ward (Debevoise & Plimpton) explain how the UK’s anti-hybrid rules may apply to a complex international private equity fund.