Barclays Wealth Trustees (Jersey) Ltd & anr v HMRC [2017] WTLR 917

Wills & Trusts Law Reports | Autumn 2017 #169

This appeal concerned the first periodic charge which fell due on a Jersey-resident discretionary trust established by the settlor, Mr Dreelan (‘the Settlor’) on 21 June 2001 (‘the 2001 Settlement’).

The Settlor transferred £100 to Barclays Wealth Trustees (Jersey) Limited (‘the Trustee’) to hold on trusts in broad discretionary form. The beneficiaries were the Settlor, his spouse and his children then living or born during the trust period. At this date the Settlor was not domiciled in the UK for IHT purposes.

The Trustee lent part of the settled funds to a wholly-owned Je...

Bowring & anr v HMRC [2015] UKUT 550 (TCC)

Wills & Trusts Law Reports | January/February 2016 #156

The appellants (CB and JB) brought an appeal against a decision of the First-tier Tribunal (FTT) on 25 June 2013 in which it dismissed the appellants’ appeals against closure notices by HMRC containing amendments to the appellants’ self-assessment tax returns for 2002-03. The effect of the amendments was that the appellants were liable to capital gains tax (CGT) of £849,644 and £317,417 respectively of additional gains under s87 of the Taxation of Chargeable Gains Act 1992 (TCGA) and supplemental charges under TCGA, s91.

In 1969, the ap...