Non-Doms, Non-Resident Clients,
Settlements And Underlying Companies
This Field Court Tax Chambers virtual conference brings delegates fully up to date with the changes in law and practice in the offshore world of individuals, companies and trusts.
- Golden trusts must be watched like a hawk and check lists for trustees, settlors and their advisers are critical.
- The FA 2020 changes for settlements must not be overlooked.
- What property holding structures should be brought into the UK and how?
- When are single premium policies useful and how does one avoid creating a PPB?
- When do treaties override the IHT “election” deemed domicile rules and when must the election be exercise?
- Are liquidations safe from s682?
- Why are there problems in source identifications (income tax) and asset location and when can HMRC use the GAAR?
- Is DOTAS a problem?
- When are loans safe and when do they devastate and when should the taxpayer use a DDS?
There is also a special session from Porus Kaka Senior Counsel India who Chambers & Partners call The International Face of Indian Tax Practice on establishing an Indian domicile for UK death duty treaty purposes and the Indian taxes to consider for UK resident Indian domiciled clients.
This is an area where nothing stops still, there are no pauses for breath! We dare you to miss this conference!
9.30am - 5.30pm
Expertise in depth
Patrick C Soares
Patrick Way QC
Philip Baker QC
Imran S Afzal
Dilpreet K Dhanoa
Porus F Kaka
Why You Should
A fantastic opportunity to hear top tax barristers discussing topical issues from the comfort of your own space
When, What, Who
- In certain circumstances it may be possible to rely on the Estate Duty Treaty with India to override a deemed UK domicile
What you must know about Indian tax law
- Establishing an Indian domicile of origin for death duty purposes
- UK/India death duty treaty from the Indian perspective
- Indian Parents leaving property to children resident in the UK – how should it be done
- UK remittances basis users who have Indian asset and income
What you can and cannot do with a Golden Trust and its underlying companies
- Dangerous loans
- Use of adjuster clauses
- IHT and tainting
- UK source income
- Service contracts
- Catch all clauses with precedents
- The OIF problem
- The insurance policy problem
- Underlying companies
- Is an anstalt a settlement
- Loans from connected settlements
- The impact of recent changes made by the MLI
- Introduction to the MLI
- The new preamble
- The generalised savings clause
- The PPT
- Tax treaties, tax planning and tax avoidance
- Property development structures
- Beware of the TAAR
- Fragmentation and enveloping
- Double Tax Treaty dilemmas
- The “new” land transaction code
- When tax might be withheld
- How do the new rules in FA 2020 affect non-domiciled settlors when assets are transferred between settlements?
- How is the relevant property regime affected?
- What about reservation of benefit under the new rules?
- How does s.80 operate?
- Is Barclays Wealth dead and buried?
- Life after the revolution
- The hidden costs of a non-resident property company
- NR CGT: direct and indirect UK land disposals
- Rebasing dilemmas
- Excluded property traps: Schedule A1
- When is it time to bring the company home?
- Onshoring Obstacles and how to avoid them