A recent case highlights the importance of meticulous implementation when tax planning. Emma Pearce explains ‘WT Ramsay v IRC [1981] was the leading authority on the approach to statutory interpretation adopted by courts to counter tax avoidance schemes.’ This article discusses the First-tier Tribunal’s (FTT) decision in Trustees of the Morrison 2002 Maintenance Trust v …
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Keith Dudley summarises the private client aspects of Sham Transactions The excellent introduction by the editors sets the scene and the following chapters 2-5 contain some fascinating and historical information and background. Some years ago Willoughby’s Misplaced Trust (second ed) by James Wadham was published by Gostick Hall Publications. As the title suggests, this book, …
Continue reading "Book Review: The real deal"
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Wills & Trusts Law Reports | April 2012 #118The husband (H) and the wife (W) were both 65, having married in 1980. There was one child of the marriage (C), aged 25. The former matrimonial home was Green Farm, a substantial property set in 72 acres in Kent. Trust assets fell to be divided following divorce.
In order to mitigate tax on the floatation of his company (ABC), two Jersey trusts were created by H in 1994 (No. 1 Trust and No. 2 Trust) and a company incorporated in the British Virgin Island called Giloch Investments Ltd (Giloch). No. 1 Trust was a discrertionary trust for a class of beneficiaries comprising H, W, C, ...
