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15 results found

Article

Squire Patton Boggs | United Kingdom | 5 Oct 2011

Double trust schemes

HMRC has issued some updated guidance on the pre-owned assets charge and in particular setting out their revised view on double trust or home loan schemes.

Article

Squire Patton Boggs | Singapore, United Kingdom | 7 Jun 2011

QROPS

I am aware that the case of Equity Trust (Singapore) Limited v HMRC has been a subject of considerable interest.

Article

Squire Patton Boggs | United Kingdom | 3 May 2011

EBTs: inheritance tax and income tax

HMRC have issued a new brief (1811) setting out their view of the inheritance tax and income tax implications of contributions to an EBT by a close company.

Article

Squire Patton Boggs | United Kingdom | 3 May 2011

Section 20 notice: possession or power

A most alarming decision has just been issued by the First Tier Tribunal in the case of Parissis v HMRC TC 1083 concerning what is meant by documents in the possession or power of the taxpayer in Section 20 TMA 1970.

Article

Squire Patton Boggs | United Kingdom | 5 Jan 2011

Employee benefit trusts

Employee benefit trusts (EBTs) and employer-funded retirement benefits schemes (EFRBSs) have been dealt a crushing blow by the draft clauses for the Finance Bill 2011.

Article

Squire Patton Boggs | United Kingdom | 30 Nov 2010

Holding UK property

Advice is often sought about how a resident but foreign domiciled client should hold residential property in the UK.

Article

Squire Patton Boggs | United Kingdom | 30 Apr 2010

Inheritance tax: omissions

An interesting decision has been published by the Tax Tribunal relating to the question whether the deferral of retirement benefits by a pensioner represented an omission to exercise a right, giving rise to a transfer of value for inheritance tax purposes: Fryer (Executor of Patricia Arnold Deceased) v HMRC.

Article

Squire Patton Boggs | United Kingdom | 30 Sep 2009

Capital gains tax: flip flops on offshore trusts

The Tax Tribunal has recently heard the case of Burton and Others v HMRC TC156 which concerns a flip flop arrangement in respect of an offshore trust.

Article

Squire Patton Boggs | United Kingdom | 30 Sep 2009

Company residence: a new and helpful decision from the Tax Tribunal

The Tax Tribunal has recently considered the question of corporate residence in the case of Laerstate BV v HMRC.

Article

Squire Patton Boggs | United Kingdom | 31 Jul 2009

Foreign tax credits: trustees are entitled to tax credits after all

HMRC has issued a statement apologising for wrongly denying trustees the right to claim the new UK tax credit on foreign dividends.

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