Overview

The fourth edition has been completely updated and revised to cover all areas of trust taxation but with a greater focus on estate planning. New areas covered include: The statutory residence test - this is considered in detail including pre-and post-emigration tax planning matters. One of the authors was closely involved in the design of this test. The new inheritance tax restrictions on debts and liabilities are analysed and HMRC's change of approach on the situs of specialty debts is considered. Practical points in structuring debt are highlighted Annual tax on enveloped dwellings and capital gains tax on non-resident companies. An entire section is devoted to these new taxes and to the options in terms of holding high value residential property generally. The new spouse exemption for foreign domiciliaries Consideration of foreign entities including partnerships and usufructs GAAR and tax avoidance generally: this is considered at length in the context of private client planning - one of the authors was on the interim GAAR committee that approved the first Revenue GAAR guidance Recent inheritance tax cases in the context of business property relief and carve outs Update on disabled trusts following FA 2013 changes New inheritance tax and capital gains tax planning techniques for the family home including use of trusts. The original chapter has now been split into three new chapters with separate discussion of past schemes, what to do with home loan schemes where clients have died, how foreign domiciliaries and non-UK residents should hold UK property and the pros and cons of different structures. This important title is not limited to a simple discussion of taxation of trusts, but covers all aspects of estate planning generally for individuals with a particular focus on use of trusts. The taxation of beneficiaries and settlors as well as trustees of UK resident and non-resident trusts is considered.

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