More Essays in International Tax Planning
Author: Milton Grundy
Publication date: 01/01/2007
Topics Covered :
This book has six chapters. In the first, the author discusses the use of London as an “offshore centre”, and explains that many – if not most – things which can be done in the well-known zero-tax jurisdictions can be done – for the benefit of non-residents, that is – in the United Kingdom.
Chapter 2 is a note of a little-explored aspect of taxation, which the author describes as the “Uncertainty Principle”. His starting point is the UK case of Franklin v. CIR (15 TC 464), and he gives some examples of the principle that profits cannot be brought into account for tax purposes at a time when the taxpayer is not entitled to them.
The “thin trust” – the settlement for the prime benefit of the settlor – is the subject matter of the third chapter. Such trusts may be established not only in the zero-tax jurisdictions, but also in New Zealand, Canada, the United Kingdom, Australia, India, Israel, Singapore and South Africa. This chapter also discusses the treaty shopping possibilities of trusts in Barbados and Cyprus.
In chapter 4, the author looks at what the offshore world can offer to the UK taxpayer. He describes the offshore company not susceptible to charges to income tax or capital gains tax, and looks at offshore trusts and partnerships and various transactions of a commercial nature.
“International Tax Planning Through Life Assurance” is the title to chapter 5. Policies taken out with insurance companies in the United Kingdom, Luxembourg and Ireland are of particular interest in that they have treaty shopping possibilities. The last chapter is a discussion of retirement to various global destinations in Europe, affording the reader a bird’s eye view of the tax regimes he may expect to encounter in each of them.
Milton Grundy studied at Cambridge under F.R. Leavis; he taught in the preparatory department of RADA while he passed his Bar exams; he was called in 1954; he first practised in the chambers of Sir John Foster, and in 1965 he founded the Gray’s Inn Tax Chambers.
He has always maintained a foothold in the world of the arts. He is author of Venice: an Anthology Guide and co-author of Mediterranean Vernacular, and he is chairman of the Warwick Arts Trust.
He has written books on tax - including, his Essays in International Taxation (Key Haven, 2001). His interest, and his practice, lie in the tax aspects of cross-border transactions and the planning opportunities they offer. He does not appear in Court, but he does chair (and very occasionally speaks at) meetings of the International Tax Planning Association, of which he is President.
Chapter 1 London as an Offshore Centre
Chapter 2 The Uncertainty Principle: A Note
Chapter 3 The Zero-tax Trust
Chapter 4 The Offshore World and the UK Taxpayer
Chapter 5 International Tax Planning Through Life Assurance
Chapter 6 A Place in the Sun