Overseas Chambers of Peter Harris

Maison de la Boucterie
Rue de la Boucterie
Saint Saviour
Jersey, JE2 7ZW

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This article has been withdrawn from public circulation as it gave too much away firstly to certain professionals who felt it appropriate to use it without paying for the further advice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 advice.

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 analysis.

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 peter.harris@overseaschambers.com for assistance.