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Trusts & estates
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Trusts & estates
TRUSTS ESTATES
A simplification of the offshore income gains rules?
Liz Fothergill
The reclassification of OIGs may appear to be a narrow technical adjustment
solely related to the operation of the temporary repatriation facility, but it has
wider practical implications, as Liz Fothergill (Mercer & Hole) explains.
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new loan charge settlement scheme may resolve many cases
but offers limited benefits for higher-value cases, writes David Pett
(Temple Tax Chambers).
Rethinking family business succession following the BPR changes
Liz Ritchie
Liz Ritchie (Forvis Mazars) considers how taxpayers are responding to the changes to Business Property Relief.
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.
BPR/APR changes in relation to relevant property trusts: planning points
Helen Lewis
Helen Lewis (Tolley) considers what planning can be undertaken to maximise
the relief available now and in the future.
No relief for reliefs: BPR and APR changes
Andrew Kerr
Emma Heelis-Adams
The draft legislation capping 100% BPR and APR has been published.
Emma Heelis-Adams and Andrew Kerr (Burges Salmon) explore the details.
Legislation day 2025: The APR and BPR reforms: sobering reading
Stuart Maggs
The Government might have consulted but it hasn’t listened.
FA 2025 EOT rules and the impact on valuations
Ritchie Tout
The recent changes to the Employee Ownership Trust rules bring the regime
back to its intended purpose – and may impact many valuations, writes
Ritchie Tout (Azets).
Equitable ownership and VAT: legal mysteries and potential answers
Fabian Barth
VAT law struggles to address the distinction between legal and equitable
ownership, but case law can provide some answers, writes Fabian Barth
(Alvarez & Marsal).
APR and BPR reform: time to make hay while the sun shines?
Emma Haley
Hayden Bailey
After a wait of four months for more detail on the changes, what does
the consultation document now tell us? While there are some helpful
clarifications, not all of the concerns are addressed, write Hayden Bailey
and Emma Haley (Boodle Hatfield).
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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
Corporate residence: beyond the paperwork
The Nigel Blackwell Family Trust and others v HMRC
Loans to participators: s 455