HMRC has published draft guidance, for comment, for inclusion in a new authorised contractual scheme (ACS) manual. The guidance does not cover SDLT and capital allowances and HMRC warns that the guidance on CGT may be amended.
Jackie Wheaton answers a query on whether interest has a UK source, reviewing the key issues following Perrin v HMRC
The scheme involved ‘gifting’ gilts to a charity subject to option and security arrangements which ensured that 99% of the gilts would be passed on to a trust set up for the benefit of Mr Ferguson and his family.
IHT: transfer to personal pension fund
Income tax scheme failed
Andrew Goldstone and Victoria Howarth provide an update on recent developments affecting the taxation of private clients.
In responding to HMRC’s plans to extend CGT to non-residents in certain circumstances, the Chartered Institute of Taxation (CIOT) has voiced concern over the proposed withdrawal of the principal residence election for all taxpayers.
Rectifying a deed of variation for IHT purposes
Jeremy Glover answers a query on an outstanding loan from a subtrust within an EBT