PRIVATE CLIENT TAXES

Jihao Zhang

Consultant Jihao Zhang works through eight scenarios for offshore trusts under the new long-term residence test, covering living and deceased settlors, the IHT tail, transitional protections and the £5m cap.

Penny Cogher

Penny Cogher (Irwin Mitchell) examines the extension of IHT to pension funds from April 2027, including the new concept of ‘notional pension property’, expanded liability for tax, and the significant practical and administrative challenges for PRs, schemes and beneficiaries.

Helen McGhee

Lynnette Bober

There were several measures introduced by the 2025 Budget that will be of particular interest to HNW internationally mobile individuals, and I highlight a few of these below. 5m IHT cap for pre-October 2024 EPTs: There will be a 5m cap...

Helen McGhee

Tweaks rather than reversals.

Paul Townson

James Flint

Paul Townson and James Flint (BDO) consider whether a sale to an EOT is still the best route for a potential future sale of a privately owned trading business.

Sarah Richards

Sarah Richards (Sedulo Tax Advisory) explains why establishing a UAE image rights structure does not in itself remove UK tax exposure.

Alyssa Haggarty

Claire Weeks

Changes to non-doms and IHT have dominated the year, but there have also been some interesting cases, write Claire Weeks and Alyssa Haggarty (Maurice Turnor Gardner).

May Smith

Emily Szasz

May Smith and Emily Szasz (Freshfields) examine some of the key tax considerations that arise in relation to the transfer of assets into a continuation fund.

Klara Kronbergs

Edward Reed

In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes) consider some of the more nuanced aspects of the non-dom reforms, as well as some key tribunal decisions affecting private clients.