Foreign Domiciliaries and Offshore Trusts and Companies Post Finance Acts 2017
Delegates may register for either or both parts
£750 + VAT (£150) = £900 for both sessions
£450 + value added tax (£90) = £540 for either the morning or afternoon session
Early booking fee for bookings received before May 27th
£650 + VAT (£130) = £780 for both sessions
£400 + VAT (£80) = £480 for either the morning or afternoon session.
Robert Venables Q.C. (Chairman)
All the speakers except Peter Vaines all from Old Square Tax Chambers, Lincoln’s Inn, WC2A 3UE, 020 7242 2744, firstname.lastname@example.org.
While, as a result of the general election, the Finance Bill, published in March 20th, will now be divided into two Finance Acts, virtually all of the relevant provisions will be retrospective to April 6th 2017.
It contains the most important changes to the taxation of foreign domiciliaries for several years.
HMRC has also slipped in other provisions particularly relating to offshore trusts and companies which also affect UK domiciliaries and non-UK residents.
Even after the Finance Bill becomes law, much can be done by way of forward planning by those not yet UK domiciled (or deemed domiciled) or not yet UK resident.
The proposed changes to the rules re capital payments from offshore trusts have been shelved for the moment but will inevitably return in one form or another. There is thus an extended window to forestall their application.
A panel of barristers will discuss tax planning in the light of the Finance Bill and likely future changes.
09.00 Delegate Registration
09.30 Chairman’s Introduction followed by
Taxation by Intimidation – An Overview – Robert Venables Q.C.
HMRC’s current conduct – Threatening and Bluffing – The GAAR – GAAR penalties – Enabler Penalties: are they that bad?
10.00 The New Deemed Domicile Rules – Harriet Brown
Long-term Residents – Residents with United Kingdom domicile of Origin – Interaction with Residence Rules – Excluded Property Settlements –
10.45 Discussion Session with Refreshments
11.00 Inheritance Tax on Indirectly Held UK Residences – Oliver Marre
The New Rules – Properties Held in Companies, Trusts and Partnerships – Creditor’s Rights – Planning
11.45 Protected Income and Gains of Settlements, Trusts and Companies – Setu Kamal
New categories of “protected income” – Income Tax (Trading and Other Income) Act 2005 Settlement Provisions – Transfer of Assets Abroad Provisions – Latest Proposals for Protected capital gains of trusts, settlements and companies
12.30 End of Morning Session – Buffet Lunch
13.30 Registration for those attending Afternoon Session only
14.00 Chairman’s Introduction to Afternoon Session follow by:
Offshore Trusts and Companies – Robert Venables Q.C.
Application of Deemed Domiciles Rules to Anti-avoidance Provisions, especially Participators in Offshore Companies (TCGA Sections 13 – 14A). Transfer of Assets Abroad Provisions: Income of Offshore Trusts, Income of Offshore Companies, Protected Arrangements; New Rules Re Relevant Income and Benefits: Retrospective “Unwashing” of Washed Income ? – New Charge on Settlors and Transferors; Beneficial New Valuation Rules for Benefits Conferred.
14.45 Tax Planning for Non-UK Domiciled or Non-UK Resident Directors and Employees – Mary Ashley
15.30 When are Income and Gains Remitted? – Peter Vaines
The Basic Rules – Special Cases
16.15 Discussion Session with Refreshments
16.30 Preemptive Planning – Robert Venables Q.C.
Planning for Those Not Yet (Deemed) United Kingdom Domiciled and / Or Resident – Planning in Anticipation of New Capital Payments Rules
17.00 Panel Session and Questions to Speakers
17.30 Close of Seminar
Booking information can be found here.
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