04 March 2021 - Events
Advising a trustee in connection with a tax-efficient distribution of assets (circa £100m) from an EFRBS to an individual in Italy; consideration of treaty; consideration of disclosure requirements.
Advising a US law firm with a London office on the tax and reporting aspects of excepted group life arrangements; drafting trust documentation.
Advising an internationally mobile employee on the UK taxation and NICs implications of employment-related securities options; reclaiming overpaid tax and NICs from HMRC.
Advising a Chinese entrepreneur in connection with the statutory residence test; practical application of the ‘work tie’ in this context; consideration of ‘exceptional circumstances’ in the light of the COVID-19 pandemic.
Advising a UK resident but non-UK domiciled individual on various matters including the establishment of an investment structure and remittance planning.
Advising two UK resident individuals on tax-efficient property trading transactions; consideration of various anti-avoidance provisions, including transfer of assets abroad and transactions in land provisions.
Advising a Guernsey trustee of a former QROPS in relation to historic issues, including a court application for rectification of the scheme trust deed and rules, and/or to have certain transactions set aside on Hastings-Bass grounds.
Advising a UK employer on the design of a bespoke salary sacrifice arrangement to make available ultra-low emission vehicles to its staff.
Advising numerous individuals, trustees, and sponsoring employers on the UK tax and NICs implications of EFRBS, including pre-A Day (FURBS) and corresponding schemes; consideration of PAYE obligations; double tax treaties; s.615 schemes.
Advising US insurance companies and other interested persons on the design of novel and tax-efficient life insurance products for UK resident and/or domiciled individuals; scope of personal portfolio bond provisions.
Advising resident and non-resident individuals and trustees on the taxation of UK real estate (residential and commercial); use of holding structures; de-enveloping exercises; interest relief; SDLT; inheritance tax; VAT issues.
Advising on pension arrangements in Malta, Jersey, Guernsey, Isle of Man, Gibraltar, Bermuda, Switzerland, the US, and Hong Kong; especially on the interaction between domestic (non-UK) legislation and the requirements relating to QROPS, QNUPS and OPS; drafting all scheme documentation, including contract-based QNUPS.
Pre-immigration planning; re-basing exercises.
Advising on EBTs and similar arrangements, including the implications of the loan charge; releasing debt and winding up; agreeing terms of HMRC settlement agreements; possible application of equitable remedies including Hastings-Bass and/or equitable mistake.
Advising on the scope of HMRC’s information and investigation powers; advising on the validity of discovery assessments issued in various circumstances.
England and Wales, 2008
The Taxation of Private Pension Schemes and their Beneficiaries (Sweet & Maxwell; 3rd edition August 2020).
Sweet & Maxwell’s Law of Pension Schemes (looseleaf) (co-author).
Parry: pension transfers and omissions (Tax Journal, 18 September 2020).
Sippchoice: the meaning of contributions ‘paid’ (Tax Journal, 25 June 2020).
Sippchoice and Bayonet Ventures: HMRC’s misguided approach to pension schemes (Tax Journal, 28 June 2018).
Association of Pension Lawyers
QNUPS: an overview (webinar given to the Federation of European Independent Financial Advisers, November 2020).
FA 2017 changes to the taxation of non-UK pension schemes (seminar given to the International Association of Consulting Actuaries, London, February 2020).
Recent changes to the taxation of benefits from non-UK pension schemes (seminar given to the Jersey Pensions Association, Jersey, September 2019).
Recent changes to the taxation of benefits from non-UK pension schemes (seminar given to the Guernsey Association of Pension Providers, Guernsey, September 2019).
Recent changes to the taxation of non-UK pension schemes and pension benefits (seminar given to the Association of Pension Lawyers, London, May 2018).
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