Sophie Dworetzsky and Catrin Harrison (Charles Russell Speechlys) consider what is meant by ‘settlor’ in the context of the protected settlement and tainting rules.
The Finance (No. 2) Act 2017 came into effect over three years ago and with it the concepts of deemed domicile under the 15 out of 20 years rule protected foreign source income (PFSI) and tainting among others. It might be assumed that advisers would have got used to these rules by now and that the legislation would have ‘bedded down’. However the legislation continues to be challenging. Complexities anomalies and drafting defects are still coming to light. One area where such issues are particularly rife is that of protected settlements and tainting.
Protected settlements and tainting
As is well known non-UK resident trusts settled by UK resident non-domiciliaries who were not...
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Sophie Dworetzsky and Catrin Harrison (Charles Russell Speechlys) consider what is meant by ‘settlor’ in the context of the protected settlement and tainting rules.
The Finance (No. 2) Act 2017 came into effect over three years ago and with it the concepts of deemed domicile under the 15 out of 20 years rule protected foreign source income (PFSI) and tainting among others. It might be assumed that advisers would have got used to these rules by now and that the legislation would have ‘bedded down’. However the legislation continues to be challenging. Complexities anomalies and drafting defects are still coming to light. One area where such issues are particularly rife is that of protected settlements and tainting.
Protected settlements and tainting
As is well known non-UK resident trusts settled by UK resident non-domiciliaries who were not...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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