The 2nd supplement updates the main 4th edition, key revisions to the title include:-
- Chapter 5: Domicile, deemed domicile. This chapter discusses the proposed changes to foreign domiciliaries (effective date yet to be determined) and practical issues arising out of the proposed change from 17 years to 15 years for inheritance tax purposes. This discussion is based on the draft legislation produced in March 2017.
- Chapter 35: Relevant property settlements. The case-law on scrip dividends is discussed and particularly the case of Seddon v HMRC. The major changes in 2015 to the relevant property regime and the planning implications for trustees are discussed.
- Chapter 44: Tax efficient will drafting. There are minor modifications to transferable nil rate bands and a major new section is inserted to cover the residential nil rate band.
- Chapter 47: Pilot trusts. The changes in respect of relevant property trusts from November 18, 2015 are discussed. The continuing advantages of using multiple trusts are also considered.
- Chapter 54: UK residential property and foreign domiciles. This chapter has been rewritten to incorporate the extensive changes to the capital gains tax regime for non-residents on residential property and the changes to tax relief on interest as well as SDLT and ATED changes. There is a discussion of what is UK source income in the light of recent case-law. The new proposed IHT charge on residential property held in enveloped structures is considered.
- Chapter 64: SLTD and stamp duty. Update on rates; discussion of new additional 3% rate and when it applies.
