Articles & Video
Complex offshore structures – traps and pitfalls: a practical guide
There has been a growing trend over recent years for the development of bespoke and complex holding structures to accommodate the needs and sensitivities of ultra-high net worth individuals. Often, the clients originate from civil law jurisdictions and as a consequence are unfamiliar with trusts and the fiduciary relationship created. There is (understandably) suspicion.
Requirement To Correct Tax Due On Offshore Assets
As HMRC continue their mission to stamp out offshore tax evasion new legislation could result in many inadvertent casualties. The Requirement to Correct (RTC) legislation imposes significant fixed penalties and sanctions if underpaid tax is discovered as being owed in relation to offshore assets.
I can see clearly now…
In recent years, there has been a positive deluge of reporting initiatives affecting UK individuals, entities and structures with a UK connection. Some of these have come from the USA (so-called “FATCA”), some from the OECD (the Common Reporting Standard), others from the EU (as a result of the 4th Anti Money Laundering Directive) and others are simply ground-breaking initiatives by the UK government.
Tax Reform - Estate and Gift Tax Update
Following President Trump’s signing of the Federal tax bill on 22 December 2017, the effective lifetime Estate and Gift Tax exemption for US citizens & residents (domiciled) has increased from $5.49m in 2017 to approximately $11.2m per individual (approaching $22.4m for US citizen or US domiciled married couples) with effect from 1 January 2018. The inflation adjustment factor has not yet been finalised.