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21 February 2008 / Judith Inghams
Issue: 7309 / Categories: Features , Public , Tax , Commercial
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A rush of blood to the head?

Changes to Capital Gains Tax for non-domiciliaries create as many anomalies as they remove, says Judith Ingham

For the second time in as many years, an innocent sounding heading in an HM Revenue & Customs (HMRC) note conceals an upheaval in the world of trusts taxation. On the first occasion, it was “alignment” in the 2006 Budget Notes which heralded fundamental changes to the inheritance tax treatment of trusts contained in the Finance Act 2006. This time, it was the label “anomalies” in the 9 October 2007 Pre Budget Report (PBR) which was the signpost to a revolution in the Capital Gains Tax (CGT) treatment of trusts made by non-domiciliaries. And, this time, there is a further sting in the tail—the draft clauses issued on 18 January 2008 (which it is proposed should be included in the Finance Bill 2008) went a lot further than the PBR implied. And, following significant lobbying since 18 January, we now have a raft of clarifications (some published in an HMRC letter of 12

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MOVERS & SHAKERS

Anthony Collins—William Hallett & Lorna Scully

Anthony Collins—William Hallett & Lorna Scully

Anthony Collins hires two talented legal directors

Switalskis—five appointments

Switalskis—five appointments

Firm expands national abuse compensation team

Mathys & Squire—nine promotions

Mathys & Squire—nine promotions

IP firm announces new partners and senior promotions across UK offices

NEWS
A High Court ruling has sent a jolt through the legal profession after a newly qualified solicitor used an internal AI tool to produce court correspondence containing a fabricated legal citation
A significant data privacy ruling has clarified what counts as valid consent under UK data protection law
Executors may be overlooking billions of pounds in estate assets hidden in forgotten investments and misplaced share certificates
Britain’s booming non-surgical cosmetics market is operating in what some critics describe as a regulatory ‘Wild West’
Family contact disputes are becoming an increasingly prominent feature of Court of Protection litigation
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