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Trust Taxation and Private Client Tax Planning 5th ed

ISBN13: 9780414059900
Previous Edition ISBN: 9780414062122
Published: April 2024
Publisher: Sweet & Maxwell Ltd
Country of Publication: UK
Format: Hardback, 2 Volumes
Price: £295.00

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This highly anticipated fifth edition of Trust Taxation and Private Client Tax Planning (formerly Trust Taxation and Estate Planning) has been completely updated and revised since it was last written in 2013, to cover all areas of private client taxation planning, including precedents.

The text has been brought completely up to date and features numerous new chapters including:

  • New and updated chapters on the major changes on the taxation of foreign domiciliaries
  • A rewrite of most chapters including excluded property trusts, insurance schemes, residence, domicile, taxation of UK real estate, SDLT and IHT and CGT planning chapters
  • New chapters on Trusts Register DOTAS and GAAR
  • New chapters on family investment companies and deferred share schemes
  • A new chapter on EU law and the post-Brexit situation

Equity and Trusts, Taxation
Part I: General
1. The Trust
2. Foreign Entities and Trusts
3. EU Considerations for Private Clients
Part II: Residence and Domicile Issues for Individuals
4. Residence Status of Individuals Before April 6th 2013
5. Residence Status of Individuals from April 6th 2013
6. Domicile, Deemed Domicile and Domicile by Election
7. Residence of Trustees, Personal Representatives and Companies
8. Taxation of Non-residents and Foreign Domiciliaries
Part III: Income Tax
9. Non-Settlor-Interested Trusts
10. Settlor-Interested Trusts—Income Tax
11. Non-Resident Trusts—The Foreign Dimension
Part IV: Capital Gains Tax
12. Definitions
13. Creation of a Settlement
14. Actual Disposals
15. Deemed Disposals of Trustees
16. UK Resident Settlor-Interested Trusts
17. Roll-Over Relief
18. Entrepreneurs' Relief
19. Incorporation Relief
20. Enterprise Investment Scheme Relief and Seed Enterprise Investment Scheme Relief
21. Share Sales, Deferred Consideration, Company Buy-backs and Priority of Reliefs
22. Hold-Over Relief
23. Non-resident Trusts Set up by UK Resident and Domiciled Settlors—the Settlor Charge under s.86
24. Non-resident Trusts Set Up by Non-UK Resident, Dead o Foreign Domiciled Settlors: The Beneficiary Charge under s.87
25. Offshore Income Gains
26. The Disposal of a Beneficial Interest
27. Loss Relief
Part V: Inheritance Tax
28. Inheritance Tax, Reservation of Benefit and Pre-owned Assets Income Tax—An Introduction
29. The 2006 IHT Rules—an Overview
30. IHT Definitions and Classifications
31. Creation of Settlements
32. The Tax Treatment of Qualifying and Non-Qualifying Interests in Possession and Reversionary Interests Including Valuation Issues, Leases and Reliefs
33. Purchases of Trust Interests
34. Melville Schemes
35. When IHT is Charged on Qualifying Interest in Possession Trusts (including Transitional Relief)
36. Immediate Post-Death Interests and Interests in Possession Held by Companies
37. Taxation of Relevant Property Settlements
38. Accumulation and Maintenance (A&M) Trusts
39. Excluded Property, Foreign Inheritance Tax Issues and Non-Domiciliaries
40. Liabilities
41. Reservation of Benefit and Settled Property
42. Pre-Owned Assets Income Tax Regime
Part VI: Specialist Topics
43. Trusts for Minors and Bereaved
44. Trusts for Vulnerable and Disabled Beneficiaries
45. Reverter to Settlor Trusts
46. Tax Efficient Will Drafting
47. Deeds of Variation, Disclaimers and other Post-Death Rearrangements
48. Tax Issues for Personal Representatives
49. Pilot Trusts
50. Bare Trusts
51. Tax, Trusts and Divorce
Part VII: Houses, Chattels and Tax Planning Generally
52. General Considerations and the Fate of Past IHT Schemes
53. Capital Gains Tax Considerations—Principal Private Residence Relief
54. Taxation of High Value Residential Property
55. IHT Planning Opportunities for the UK Domiciliary
56. Foreign Domiciliaries and Family Home
57. Stamp Duty Land Tax
58. Chattel Schemes
Part VIII: Business Structures
59. Businesses: Business Property Relief
60. Farms: Agricultural Property Relief
61. Employee Benefit Trusts
62. Partnership Structures
63. Taxation of Non-resident Companies
>b>Part IX: Investments
64. Life Policies and Other Insurance Products Held in Trust
65. Pension Arrangements
Part X: DOTAS and Compliance
66. Compliance Requirement to Correct
67. Disclosure