Key Haven Seminar

Foreign Domiciliaries and Offshore Trusts and Companies Post Finance Acts 2017 FULL DAY Delegates may register for either or both parts Delegate Fees £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. Speakers Robert Venables Q.C. (Chairman) Peter Vaines Harriet Brown Setu Kamal Oliver Marre Mary Ashley All the speakers except Peter Vaines all from Old Square Tax Chambers, Lincoln’s Inn, WC2A 3UE, 020 7242 2744, 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. TIMETABLE 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. Conferences Terms and Conditions Cancellations in writing 14 days prior to the seminar qualify for a refund subject to a £50 charge. Cancellations within 14 days prior to the seminar do not qualify for a refund. Disclaimer: Key Haven Publications Ltd reserves the right to change the speakers or the programme for any reasons beyond its control or on account of changes in the law. Nothing in the talks or discussions or the prepared notes constitute legal advice. They are simply an expression of the speakers’ views, put forward for consideration and discussion. No action should be taken nor omitted in reliance on them but independent professional advice should be taken in every case. Neither the speakers nor Key Haven Publications Ltd accept any legal responsibility for them. Warning: Neither Key Haven Publications Ltd nor the speakers gives any licence to any person to record and/or reproduce in any format (including sound and/or visual recording) (a) any Notes prepared in conjunction with this seminar; (b) the delivery by any speaker of any talk or any response to any question or discussion, in whole or in part, on any of the above. Any such unlicensed recording or reproduction or the making of any such epitome or transcript is a civil wrong and could well involve the commission of a criminal offence.]]>

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