Pre Budget Report 2007 - Inheritance Tax

Any assets passing on death to a spouse or civil partner normally qualify for spouse exemption and no inheritance tax is payable. However, each individual is entitled to a nil rate band allowance (currently £300,000) and, essentially in this scenario, the nil rate band on the first death goes unused. With the use of tax planning Wills, there have been various ways in which the first nil rate band could be rescued.

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Pre Budget Report 2007 - Initial response

The immediate reaction to the Chancellor’s speech is that much of what he said was smoke and mirrors – The Inheritance Tax doubling of the nil rate band is not quite what it seems – 2 x 300,000 is still 600,000 so far as I know…

The capital gains tax simplification represents a significant increase in tax in a number of cases and if you are non UK domiciled and UK resident then keep checking this page. We are writing frantically as I type and a more detailed and coherent response will follow shortly….

Bad news for US beneficiaries of foreign trusts

Last month the American version of HM Revenue and Customs, the IRS published a radical “technical advice memorandum” (TAM) which set out its view that US beneficiaries of offshore (i.e. non US) trust / holding company are taxable on a corporate reorganisation within the structure under the Passive Foreign Investment Company (PFIC) rules.

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Nothing for nil rate band on death?

Our new edition of Tax Plus is now online for your reading pleasure.

Current articles include:-

  • The tale of Mrs. Phizackerley
  • Limit loss relief
  • A&M trusts
  • Double your pension money!

and much more can be located

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