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A Key Haven Intelligence Report

Non-Resident Trusts 9th Edition

Robert Venables Q.C.

The Work

ROBERT VENABLES’ NON-RESIDENT TRUSTS is firmly established as a seminal and leading work on the UK taxation of non-UK resident trusts and settlements, their trustees, settlors and beneficiaries.

To mark the 20th anniversary of the appearance of the 1st edition of this Report, Robert Venables is preparing a new edition which will be no mere updating of the 8th edition but will involve a substantial re-writing of the text to take into account the many important changes in this area in recent years and particularly the changes planned to be effected by Finance Act 2008.

This Report will not simply be an academic account of the new law but will offer pragmatic tax planning advice. It will build on the author’s considerable experience as a tax barrister over a period of almost thirty years, eighteen of them as one of Her Majesty’s Counsel, in advising on the UK taxation of UK and foreign trusts, companies and foreign institutions and persons connected with them.

This Intelligence Report is intended primarily for barristers, solicitors, advocates and other lawyers, accountants, chartered tax advisers, professional trustees, officers of trust corporations, financial advisers and other professionals.

The Author

Robert Venables Q.C. is an acknowledged expert on taxation, particularly the taxation of trusts, inheritance tax and offshore and international taxation. He is the author of several seminal works on trusts and taxation, including The Taxation of Trusts 2007 (with Finance Bill 2008 Supplement) and Inheritance Tax Planning.

In the course of his practice at the bar over the last quarter century (and particularly since being appointed Queen’s Counsel in 1990) he has advised on sophisticated planning for many trusts, both at home and abroad, and appeared in landmark cases in the House of Lords, the Privy Council and the European Court of Justice, as well as in the Court of Appeal and High Court. Famous cases involving trusts and/or inheritance tax in which he has appeared include Lady Ingram, Jerome v Kelly, R v Dimsey, and Marshall v Kerr in the House of Lords and Howell v Trippier in the Court of Appeal.

He was Chairman of the Revenue Bar Association of England and Wales 2001-05, is a Master of the Bench of the Middle Temple and a Fellow and Council Member of the Chartered Institute of Taxation. He was a full-time Oxford law don in the 1970's and is now a non-executive Fellow of the college of St Edmund Hall, in the University of Oxford.

CONTENTS

The precise contents have yet to be finalised, particularly as we are warned that parts of the Finance Bill 2008 will be subject to government amendments.

The Report will concentrate on Capital Gains Tax and include some discussion of income tax, especially the Transfer of Assets Abroad Provisions and Settlement Provisions.

Particular emphasis will be placed on the changes to be effected by Finance Act 2008, particularly in regard to:

• non-UK domiciliaries,

• capital gains tax

• taxation of UK domiciled and resident beneficiaries of non-UK resident trusts

Further details as to the contents will be announced in due course.