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Home
IHT
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IHT
IHT
Home, a loan: the Court of Appeal’s ruling in Elborne
Louis Triggs
Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.
Loans from non-UK resident trusts: UK tax traps
Alice Martin
Elena Dunn
Carolyn Steppler
Alice Martin, Elena Dunn and Carolyn Steppler (Charles Russell Speechlys) consider the UK tax and practical risks arising from offshore trust loans, including unexpected IHT exposure, settlor charges and the consequences of irrecoverable debts.
Trustees IHT exposure from 6 April 2025
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.
IHT pension tax reform: new rules, new risks
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.
Finance Act 2026
Ros Martin
Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.
Gifting APR/BPR assets on death
Simon Douglas
Simon Douglas (5 Stone Buildings) considers the will-drafting consequences of the new £2.5m allowance and its transferability – and explains why traditional ‘100% relief’ clauses may now not always achieve the desired result.
Grandfathering
John Barnett
The Government’s approach to APR and BPR reform combines delay and
anti-forestalling in a way that risks serious unintended consequences,
writes John Barnett (CIOT).
Should I stay or should I go? Life as a non-dom adviser
Rachel de Souza
Rachel de Souza (RSM UK) charts a tumultuous year for international private
clients, as sweeping changes to domicile, offshore trusts and IHT prompted
unprecedented restructuring – and, for some, departure from the UK.
Budget 2025: Budget changes to pensions
Penny Cogher
The 2,000 cap: Generally, the pensions industry, businesses (of all sizes), pensioners and individuals will heave a collective sigh of relief that the Chancellors smorgasbord Budget has stayed away from tinkering with anything more than...
Budget 2025: Complaints old and new: what the Budget really tells us about tax
David Milne KC
There will be the usual complaints about the tax burden on working people, but it is very modest compared with the 1960s and 1970s, when the top rate of income tax was still 98%, imposed to pay the USA for the monies lent to us for WW2. There will...
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EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Broad opposition to proposed ‘reckless statements’ tax offence
GfC7 points to disclosure facility for late TP corrections
Options explored for simplifying offshore anti-avoidance rules
CIOT calls for urgent changes on IHT on pensions
Normal minimum pension age protection consultation
CASES
Read all
HMRC v G Quillan
Perenco UK Ltd v HMRC
HMRC v C Candy
Property 118 Ltd and another v HMRC
Ten cases shaping tax practice in 2026
IN BRIEF
Read all
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
HMRC’s annual report for 2025/26
MOST READ
Read all
Property 118 Ltd and another v HMRC
Tax Journal thanks its July 2026 authors
Perenco UK Ltd v HMRC
When is a trustee not a trustee?
The end of offshore execution on secondary transactions