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IHT


The options for taxing wealth are challenging. Dom Rothbarth (Boodle Hatfield) assesses the Chancellor’s options.
Gary Richards, Chair of the GAAR Advisory Panel, explains how the Panel makes its assessments and what advisers can learn from its published opinions.
Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.
Card image Carolyn Steppler Elena Dunn Alice Martin
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.
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 (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.
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.
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.
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).
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.
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