Trust Taxation and Estate Planning, 5th Edition

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Trust Taxation and Estate Planning, 5th Edition

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Contents

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This essential text examines the taxation of trusts and is accessible to specialists and non-specialists. There have been many updates in this area of the law since the 4th edition published in 2014 and the 2nd supplement in 2017.

Key features of this new edition:

Covers all recent case law developments including reservation of benefit, business and agricultural property relief, employee benefits trusts and mistakes
All chapters on domicile and offshore trusts have been completely rewritten following the 2017 developments
Contains new chapters on the taxation of residential and commercial property to take account of all the major IHT and CGT legislation taxing non-residents from 2017 and 2019
Updates the compliance and disclosure chapters in the light of common reporting and requirement to correct
Updates to all the income tax chapters on trusts
A new chapter on EU considerations for private clients

Part I - General

1. The Trust
2. Foreign Entities and Trusts
3. EU Considerations for Private Clients

Part II - Residence and Domicile Issues for Individuals

4. Residence Status of Individuals Before April 6th 2013
5. Residence Status of Individuals from April 6th 2013
6. Domicile, Deemed Domicile and Domicile by Election
7. Residence of Trustees, Personal Representatives and Companies
8. Taxation of Non-residents and Foreign Domiciliaries

Part III - Income Tax

9. Non-Settlor-Interested Trusts
10. Settlor-Interested Trusts—Income Tax
11. Non-Resident Trusts—The Foreign Dimension

Part IV - Capital Gains Tax

12. Definitions
13. Creation of a Settlement
14. Actual Disposals
15. Deemed Disposals of Trustees
16. UK Resident Settlor-Interested Trusts
17. Roll-Over Relief
18. Entrepreneurs' Relief
19. Incorporation Relief
20. Enterprise Investment Scheme Relief and Seed Enterprise Investment Scheme Relief
21. Share Sales, Deferred Consideration, Company Buy-backs and Priority of Reliefs
22. Hold-Over Relief
23. Non-resident Trusts Set up by UK Resident and Domiciled Settlors—the Settlor Charge under s.86
24. Non-resident Trusts Set Up by Non-UK Resident, Dead o Foreign Domiciled Settlors: The Beneficiary Charge under s.87
25. Offshore Income Gains
26. The Disposal of a Beneficial Interest
27. Loss Relief

Part V - Inheritance Tax

28. Inheritance Tax, Reservation of Benefit and Pre-owned Assets Income Tax—An Introduction
29. The 2006 IHT Rules—an Overview
30. IHT Definitions and Classifications
31. Creation of Settlements
32. The Tax Treatment of Qualifying and Non-Qualifying Interests in Possession and Reversionary Interests Including Valuation Issues, Leases and Reliefs
33. Purchases of Trust Interests
34. Melville Schemes
35. When IHT is Charged on Qualifying Interest in Possession Trusts (including Transitional Relief)
36. Immediate Post-Death Interests and Interests in Possession Held by Companies
37. Taxation of Relevant Property Settlements
38. Accumulation and Maintenance (A&M) Trusts
39. Excluded Property, Foreign Inheritance Tax Issues and Non-Domiciliaries
40. Liabilities
41. Reservation of Benefit and Settled Property
42. Pre-Owned Assets Income Tax Regime