Usufruits and s.43(2) ITA 1984. Has HMRC forgotten what "Law" means?
April 12th 2021
This article has been withdrawn from public circulation as it
gave too much away firstly to certain professionals who felt it
appropriate to use it without paying for the further advice needed
and secondly to lay individuals who were unable to fully grasp its
content and to use it to full advantage and effect. It was
deliberately incomplete as it was a "taster" and commentary not
Please contact Peter for further advice and information on this
topic before acting. HMRC's public position published in its
manuals is fundamentally flawed both for pre-2017 and for post-2017
French usufructuary dismemberments whether taking effect on on
death or by lifetime gift and retention.
It is unadvisable to rely on advice from either a purely French
avocat or notaire or from a purely English accountant or solicitor
as the matter involves princples of international law and
interpretation that are derived from experience, not from textbook
You need advice, otherwise you would not have consulted this
link or post.
Please therefore telephone Peter Harris on + 44 (0)1534 62579 or
e-mail him on email@example.com for assistance.