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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.
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...
Private client review for November 2025
Sophie Dworetzsky
Budget blues, legitimate expectation and crypto matters are among the issues
reviewed by Sophie Dworetzsky (Lombard Odier).
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Consultation tracker
One minute with… Jon Claypole