Implied Trusts and Beneficial Ownership in Modern UK Tax Law looks at that gap which lies between books on tax and those on trust law, and tries to bridge the two. How and why is beneficial ownership important in UK tax? This book is ideal for academics and practitioners alike. Those practitioners specialising in trusts should find this book an interesting and useful aid to supplement their knowledge of implied trusts and the relationship between the more-usual express trusts. Whether you are new to the tax profession, or a seasoned professional, there will be something here for everyone.

Insurance Premium Tax is a guide for practitioners and those involved in the insurance industry. It summarises how the IPT is applied in practice, the definition of an insurance contract, looks at exemptions from the tax, the application of the higher rate and issues affecting non UK risks and global policies. It also explores compliance issues such as IPT registration, the submission of returns and payment of the tax, changes in rates and the penalty regime.

New essays by leading figures from the judiciary, practicing lawyers and academics illuminating the worlds of trusts and wealth management.

In International Taxation of Trust Income, Mark Brabazon establishes the study of international taxation of trust income as a globally coherent subject. Covering the international tax settings of Australia, New Zealand, the UK, and the US, and their taxation of grantors/settlors, beneficiaries, trusts, and trust distributions, the book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust. It also identifies international mismatches between tax settings and purely domestic design irregularities that cause anomalous double- or non-taxation, and proposes an approach to tax design that recognises the policy functions (including anti-avoidance) of particular rules, the relative priority of different tax claims, the fiscal sovereignty of each country, and the respective roles of national laws and tax treaties. Finally, the book includes consideration of BEPS reforms, including the transparent entity clause of the OECD Model Tax Treaty.

What are the contemporary challenges faced by property law as we enter the 2nd decade of the 21st century? This collection brings together the research and perspectives of an international body of academics and practitioners to consider these challenges and how even familiar topics must develop to meet new demands and developments. As with previous books in the Modern Studies in Property Law series, this volume adopts a broad approach to topics encompassed by 'property law' in the firm belief that the boundaries that divide are shadowy at best and constantly moving in the endeavour to keep up with what is 'modern'. This collection looks at 5 themes: - Comparative perspectives, including a chapter on grazing and cropping rights in Northern Ireland, and analysis of the anomalies of the English trust law as seen from a civil law perspective; - Taking and alienating property, including a chapter on bankruptcy and the family home; - Modern dilemmas, including chapters on trusts in virtual currency and on smart homes; - Old chestnuts – new challenges, including analysis of the mortgage law reform in Scotland and a chapter on the ouster principle in common law jurisdictions; and - Wills, death and other morbid topics, with chapters on English succession law and the role of knowledge and approval in retrospective assessments of capacity. Unfortunately, the COVID-19 pandemic prevented the 13th biennial conference being held in 2020 as planned but despite this, the authors and co-editors persevered to produce this interesting and diverse collection.

This report examines the use of these entities in nearly all cases of corruption. It builds upon case law, interviews with investigators, corporate registries and financial institutions and a 'mystery shopping' exercise to provide evidence of this criminal practice.

This classic textbook brings a modern perspective to the study of the law of equity. Its hallmark contextualized approach and commercial focus will help students understand the subject, and the authors' commentary on the factors informing trusts law allows students to confidently grapple with complex ideas.

Revised and extended edition of monograph on the concept of trusts, including the impact of taxation on a trust. The law is stated as of 1 January 1974.

This book is intended to meet a range of different needs and to cater for different levels of knowledge about employee ownership. If you are considering making your company employee-owned or you are advising someone going through that process, and in either case are new to the topic, you can build up your knowledge levels from Chapter 1. Alternatively, the book can be used as a reference work if you have a particular question to answer. Some parts of the book will not be relevant to every reader. For example, several Chapters consider how employees can acquire shares personally: these will not be relevant to companies which intend their employee ownership only to be through an employee trust. The book is intended as practical guide rather than a highly detailed technical treatise. Its priority is to explain key issues in an accessible fashion and to raise awareness of where further exploration and advice may be important. Chapter 1 This Chapter looks at the background to employee ownership and why companies choose to become employee-owned. Chapter 2 Employee trusts are a key part of the structure of most employee-owned companies, as outlined in this Chapter. Individual share ownership is also introduced here, as some employee-owned companies combine ownership by an employee trust (which usually holds the majority of the company’s shares) with direct, individual ownership of shares by employees. Chapter 3 Chapter 3 goes more deeply into how employee trusts work and how the role of trustees as owners interacts with the role of the company’s directors. Chapter 4 In this Chapter, the key steps and decisions that will need to be made in establishing an employee trust are considered. Chapter 5 This Chapter starts to look in more detail at individual share ownership, in particular the ways in which employees can acquire shares personally, and provides a summary of the tax reliefs that are available for individual employees acquiring shares in their company. Chapter 6 Employee ownership trusts are a particular kind of employee trust, bringing particular tax reliefs. This Chapter considers these tax reliefs and the various conditions which must be satisfied. Chapter 7 Many companies become employee-owned through the existing owners transferring their shares to an employee trust. This Chapter looks at how to plan ownership succession in this way and some key questions that will need to be considered. Chapter 8 An employee ownership trust deed is likely to form the structural core of most employee-owned companies. This Chapter explains the key provisions that it will commonly include. Chapter 9 This Chapter considers the people issues which arise in a transition to employee ownership, and has been written by Jeremy Gadd. The next five Chapters look in more detail at how employees can acquire shares individually and may be of value to companies wishing to include individual share ownership alongside trust ownership. Chapters 10 and 11 look at two tax-advantaged all-employee share schemes. Chapter 10 The Share Incentive Plan (SIP) enables employees to purchase shares or receive free shares, in each case with relief against income tax. The SIP is an all-employee share scheme, which means that all employees must be allowed to participate in any offer of shares. This Chapter looks at the statutory requirements for operating a SIP and how it works in practice. Chapter 11 Save As You Earn (SAYE) options is another form of all-employee share scheme, under which employees can be granted options to acquire shares in the future and those employees who participate will save a monthly amount towards the option exercise price. This Chapter considers how SAYE options work. Chapters 12 and 13 look at tax-advantaged share schemes which do not need to involve all employees: Chapter 12 This Chapter looks at Enterprise Management Incentive (EMI) options. For companies wishing to create personal share ownership for their key people, EMI options will often be the best place to start. There are particular eligibility requirements for EMI options. These are considered in this Chapter, which also discusses the key elements of an EMI scheme, and offers suggestions as to how EMI options can be structured. Chapter 13 An alternative to EMI options is the Company Share Option Plan (CSOP). This Chapter considers how the CSOP works. Chapter 14 This Chapter looks at other ways in which employees can acquire shares personally. Chapters 15 to 20 consider other legal, regulatory and taxation issues. Chapter 15 Where employees are to acquire shares (or cash) from an employee trust, it is important to ensure that this is structured in a way which does not fall foul of tax anti-avoidance rules which were introduced to counter what is commonly referred to as disguised remuneration. This Chapter looks at these provisions and how to keep on the right side of them. Failure to do so could result in a charge to income tax and National Insurance on the value of assets even though an employee has not acquired any definite ownership rights over them. Chapter 16 This Chapter sweeps up some other legal and regulatory matters not directly covered in previous Chapters. Chapter 17 This Chapter covers data protection requirements. Chapter 18 This Chapter covers phantom shares. Chapter 19 This looks at the interaction between corporation tax, employee trusts and different individual employee share schemes. Chapter 20 There are a number of registration and filing requirements with HM Revenue and Customs and the Registrar of Companies. This Chapter considers these and some continuing administration requirements and summarises the accounting treatment of employee trusts and employee share schemes.