Latest Articles

Bare trust/nominee agreement for company funds? - USERNAME: bbarry10201 - 18/04/2024

 Tax Question Our company has surplus balance in our currency account. (US dollar)  due to a slowdown. We get a far better return on a fixed term if the funds are placed abroad for a fixed period of one year. However The funds have to be placed in a personal name with an overseas bank. Is it possible to place the deposit in  my personal name however on behalf of the company. The principal and interest will be transferred back to the company on maturity and reflect in the company accounts. The overseas bank is aware these are company funds and no tax will be charged abroad. We can make a private agreement, or even a trust deed from or solicitor or advise HMRC, which option you think is the best so they do not treat this as a loan given to the director.... keep reading

Moving to the UK Whilst Controlling a Non-UK Company
30/06/2023Moving to the UK Whilst Controlling a Non-UK Company

Moving to the UK requires consideration of a number of tax issues. One key issue is the treatment of any foreign incorporated companies that are owned or controlled. In this article we look at the key issues.... keep reading

UK Tax Planning for Land Pooling Arrangements
28/06/2023UK Tax Planning for Land Pooling Arrangements

In this Practitioner Zone report we look at the tax treatment of land pooling arrangements, and some of the options to structure land pooling transactions tax efficiently.... keep reading

An analysis of how British citizenship impacts on domicile status
24/06/2023An analysis of how British citizenship impacts on domicile status

Obtaining a UK domicile of choice can have a significant impact on an individuals UK tax treatment (including income tax, CGT and inheritance tax). In this article we look at how obtaining British citizenship can interact with this.... keep reading

Choosing between a family trust or a family investment company
20/06/2023Choosing between a family trust or a family investment company

In this article we look at some of the factors to consider when choosing between a family trust or a family investment company.... keep reading

Recent Case on 'Double Trust' planning for IHT
13/06/2023Recent Case on 'Double Trust' planning for IHT

In this Practitioner's article, we look at a recent case of the First Tier Tribunal on IHT 'Double Trust' planning.... keep reading

Tax implications of a distribution in specie of UK residential property from an overseas company
30/05/2023Tax implications of a distribution in specie of UK residential property from an overseas company

In this Practitioner Zone report we look at the tax implications of a distribution in specie of UK residential property from an overseas company... keep reading

Establishing Non-UK Domicile for Long-Term UK Residents
26/05/2023Establishing Non-UK Domicile for Long-Term UK Residents

In this article, we look at some of the issues to be considered for long-term UK residents looking to avoid establishing a UK domicile of choice, including the impact of a recent case.... keep reading

Using a discretionary trust and deed of variation for IHT planning in 2023
22/05/2023Using a discretionary trust and deed of variation for IHT planning in 2023

In many cases, the transferable nil rate band prevents the need to create a discretionary trust on the death of the first spouse. However, this is not always the case. In this article, we look at the role of discretionary trusts and deeds of variation in 2023 IHT Planning.... keep reading

Tax on the migration of trusts
18/05/2023Tax on the migration of trusts

Following a request from one of our members we've looked in detail in this article at the UK tax implications of trusts migrating overseas. Trust migration essentially means that a UK resident trust becomes non UK resident.... keep reading

Reducing Inheritance tax (a CLT) on a transfer to an offshore company
16/05/2023Reducing Inheritance tax (a CLT) on a transfer to an offshore company

One of the often forgotten implications of a transfer to an offshore company is that this is a chargeable lifetime transfer ('CLT') for inheritance tax purposes. In this Practitioner Zone article we look at how the 20% IHT charge on a CLT to an offshore company could be reduced... keep reading

Tax Planning for Holiday Homes
15/05/2023Tax Planning for Holiday Homes

Tax planning for holiday homes doesn't just require an analysis of the inheritance tax implications, but consideration should also be given to income tax, capital gains tax and stamp duty land tax. All of these can be relevant. In this practitioner zone article we look at the key tax planning options... keep reading

Structuring a Share Sale Tax Efficiently
12/05/2023Structuring a Share Sale Tax Efficiently

In this article we look at the tax issues to consider on corporate share deals including key tax exemptions, reliefs and considerations for a tax efficient disposal.... keep reading

Timing of Gifts for IHT Purposes
04/05/2023Timing of Gifts for IHT Purposes

Gifts can be a highly effective strategy to minimise inheritance tax, however, the timing of gifts can have a significant impact on the amount of the IHT reduction. In this article we look at the timing of gifts for IHT purposes.... keep reading

Making the Most of IHT Share Loss Relief
03/05/2023Making the Most of IHT Share Loss Relief

In this Practitioner Zone report we look at the IHT loss relief for shares and how beneficiaries can take advantage of this to reduce the IHT on shares.... keep reading

Non resident partners and UK tax
27/04/2023Non resident partners and UK tax

Following a members tax question we've looked at the tax position of non resident partners. This article looks at how non UK resident partners are taxed in the UK and how they could structure their affairs to reduce UK tax... keep reading

IHT on Gifts From Life Interest Trusts
25/04/2023IHT on Gifts From Life Interest Trusts

In this Practitioner Zone report we look at the IHT position on gifts from life interest trusts.... keep reading

Bare trust's and using the annual exemption
24/04/2023Bare trust's and using the annual exemption

When someone mentions a 'trust' the usual reaction is to think of a separate trust entity that has trustees and owns and manages assets on behalf of beneficiaries. However this is not necessarily the case. This article looks at the use of a bare trust and how it can be advantageous in tax terms, particularly for using children's annual exemptions.... keep reading

How shareholders can use cross options to retain entitlement to Business Property Relief
21/04/2023How shareholders can use cross options to retain entitlement to Business Property Relief

On the death of a shareholder the question of whether the continuing shareholders have sufficient funds to buy the deceased's shares can be a significant issue. In many cases, a suitably-drafted cross-option agreement, backed by an appropriate term assurance policy is the solution. This can be drafted on a stand-alone basis or can be included as a separate section in a shareholders' agreement.In this Practitioner Zone article we look at this in more detail.... keep reading

Using trusts for tax planning
19/04/2023Using trusts for tax planning

In this Practitioner Zone report we look at some simple strategies for using trusts in UK tax planning... keep reading

UK corporation tax planning after you've left the UK
18/04/2023UK corporation tax planning after you've left the UK

If you trade via a UK company, the general rule is that it would be subject to UK corporation tax even if the controlling directors or shareholders were non UK resident. However as a non resident individual you may be looking at options to reduce the UK corporation tax charge. In this article we look at the UK tax planning options... keep reading

Using Growth Shares to Plan for a Tax Efficient Business Exit
14/04/2023Using Growth Shares to Plan for a Tax Efficient Business Exit

In this Practitioner article we look at the use of Growth Shares to structure a tax efficient business exit.... keep reading

Furnished Holiday Lets in 2023
13/04/2023Furnished Holiday Lets in 2023

In this article we look at the tax treatment of furnished holiday lettings in 2023, and the requirements to benefit from the beneficial tax treatment.... keep reading

Reducing tax on property development by using a trust
11/04/2023Reducing tax on property development by using a trust

One possibility to reduce tax on property trading is by using a trust. The general idea would be that you could save the 40% or 45% income tax charge you'd be subject to if you did the development in your own name by using a trust. The trust could be subject to income tax at the basic rate of 20%. There could therefore be a significant tax saving. Practitioner Zone report.... keep reading

The IHT Reservation of Benefit Trap
03/04/2023The IHT Reservation of Benefit Trap

The reservation of benefit rules are a very common trap for families looking to transfer ownership of the family home. In this article we look at the scope and impact of the rules.... keep reading

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