Join Us - 27 April 2021
FCTC Offshore Tax 2021:
Location: Live Online
Register
FCTC Offshore Tax 2021:
Non-Doms, Non-Resident Clients,
Settlements And Underlying Companies
Location: Live Online
Register
Event Overview
Non-Doms, Non-Resident Clients,
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!
Conference Format:
One day
Ticket Information:
£500+VAT
Running Time:
9.30am - 5.30pm
Location:
Live Online
CPD:
6½ Hours
Reasons To Attend
Why You Should
Why You Should
Attend
A fantastic opportunity to hear top tax barristers discussing topical issues from the comfort of your own space
Event Schedule
When, What, Who
The UK/Indian Estate Duty Treaty and the Deemed Domicile Override
- In certain circumstances it may be possible to rely on the Estate Duty Treaty with India to override a deemed UK domicile
Planning for Individuals Resident in the UK but Domiciled in India
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
Why you must have a Domicile Pack
- Be prepared for a potential HMRC challenge to domicile status
- Gain comfort if tax returns are being filed in reliance on non-UK domiciled status
"God's Particle" Structures
- Settlor interest settlement caught by the GROB
- Loss of spouse exemption
- Special trust clauses
- Creating an immediate post-death interest to solve the problem (IHTA 1984 s49A)
- CGT implications
Golden Trusts - Twenty Point Checklist
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
Transfer Of Assets Abroad
- How to apply the motive test
- Where are we with EU protections after Brexit?
- How are non-domiciliaries affected by the rules?
- How do the Fisher, Davies and Rialas cases help our understanding?
Double Tax Treaties
- 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
Single Premium Offshore Policies
Their strategic roles in offshore settlements - what is happening in practice
- The magic 5%
- Avoiding the PPB regime
- S730
- Golden Trusts
- Below trust level gains
- Chamberlains’ case
- Dangerous advisers
- Hermetically sealed trusts
- CGT
Non-Resident Companies Dealing in and Developing UK Land
- Property development structures
- Beware of the TAAR
- Fragmentation and enveloping
- Double Tax Treaty dilemmas
- The “new” land transaction code
- When tax might be withheld
Coffee Break
Critical Planning - IHT and
Non-Domiciliares
- Returning Non doms – use the IHT grace period
- Exempt Gilts
- Additions to trusts – new rules
- GROBS and excluded property
- UK residential property and relevant loans
- Watch out for unexpected 10 year and exit charges
Transfers Between Settlements - when the alarm bells must ring
- 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?
Non-Resident Companies Investing in UK Land and when to make them UK Resident
- 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