January 31st 2019
If you were born in the United Kingdom and are being forced to
return as a result of Brexit uncertainties, if you fall
within the definition of s.267 (1)(b) Inheriatnce Tax Act 1984 you
can now be deemed not to have lost your UK domicile for...
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January 22nd 2019
The French tax adminstration have confimed that retaining a
usufruit by making a gift of the nue-propriété is not an abus de
droit under the new rules introduced by article 109 of the
loi de finances pour 2019.
Fortunately, for the French...
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November 12th 2018
The main and indeed fatal flaw in HMRC's "view" of usufructuary
dismembemens is exposed in Keyhaven's Tax Planning Review Volume 7
published on 28th October, 2018.
HMRC has no territorial competence, constitutionally, to
adjudicate settlements...
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September 29th 2018
The recent case of JSC Mezhdunarodniy Promyshlenniy Bank v
Pugachev [2017] EWHC 2426 (Ch) or "Putin's banker" contains a
welcome analysis of what, if anything, a sham trust signifies
legally.
The phrase is frequently used as a threat by tax...
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September 27th 2018
© Peter Harris
Article : Critical omment on Pascal Chassaing's Paper in Droit
Européen des Successions Internationales, Le Règlement du 4
juillet, 2012
This article was published in the Linked In group discussion Brussels IV -
EU...
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August 30th 2018
This article merely addressed the French civil
law, and made no attempt to address usufruits in other
jurisdictions or their equivalents.
Peter has withdrawn it from public consultation as it
was much used but also abused in the sense that no one...
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August 10th 2018
There is an increasing number of private offerings being made by
French asset managers, which are available to Channel Island
investors.
Addressing the fiscal issues on such passive investments is
relatively straight forward....
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August 10th 2018
France is offering individuals, whether as
self-employed, as employees, or senior executive shareholders
of French groups who relocate to France under the Brexit
scenario a partial exemption from French income tax on foreign
income for...
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