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Budget 2026: options for taxing wealth
Dom Rothbarth
The options for taxing wealth are challenging. Dom Rothbarth (Boodle Hatfield) assesses the Chancellor’s options.
Using opinions of the GAAR Panel
Gary Richards
Gary Richards, Chair of the GAAR Advisory Panel, explains how the Panel makes its assessments and what advisers can learn from its published opinions.
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
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.
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.
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Effective consultation supports coherent and coordinated tax reform, says CIOT
Chancellor reportedly rejects alignment of CGT and income tax rates
CIOT seeks clarity on interest relief after capital withdrawals
HMRC launch online service for climate change levy returns
Consultation on plastic packaging tax
CASES
Read all
J Smith v HMRC
J Smith v HMRC
The Nigel Blackwell Family Trust and others v HMRC
Other cases that caught our eye: 16 October 2026
HMRC v British Airways plc
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Victoria Oil & Gas plc v HMRC
Bolt: Supreme Court refuses permission to appeal
Loans to participators: s 455
AI and the unwinnable case
Modernising the taxation of distributions