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Four new Articles and Editorial added to the Tax Planning Review 27.11.13

Written by on 27/11/2013 12:45

Four new articles and an editorial have been added to the Tax Planning Review Volume 2 @ 27.11.13:

Editorial by Malcolm Gunn (editorial also printed below)

TPR Vol.2.3 

‘Director and Employee Remuneration’  –  Andrew Thornhill Q.C.

TPR Vol.2.4

‘IHT Deduction for Debts Attributable to Excluded Property Post 2013’  James Kessler Q.C.

TPR Vol.2.5

‘Some Problems With The GAAR’  Patrick Cannon

TPR Vol.2.6

‘Rectifying Mistakes after Supreme Court decision in Futter v Futter and Pitt v Holt’  Harriet Brown

The new material can be accessed by logging into the Reviews section at the Key Haven website

TPR Editorial by Malcolm Gunn @27.11.13

This issue of the Tax Review contains four articles based a sessions at this year’s Key Haven Annual Tax Planning conference held at Merton College Oxford. All are on highly topical matters and readers will, I believe, find them to be more comprehensive than anything offered elsewhere in the tax press. I hope to include more articles based on other sessions in the next issue.

Andrew Thornhill QC looks at tax planning for director and employer remuneration, and advises on what courses of action remain open in relation to existing EBTs

James Kessler QC considers detailed aspects of the new Finance Act 2013 provisions for debts attributable to excluded property, including a critical review of HMRC’s newly published comments in the IHT manual.

Harriet Brown provides a full update on the rule in Hastings Bass from a viewpoint of both UK law and Jersey law, where there is now considerable divergence from the position in the UK.

Patrick Cannon offers a detailed analysis of the new General Anti-Abuse Rule with particular reference to how past decisions on other anti-avoidance provisions may assist in how the new rule may in practice.

Articles on UK tax law and practice are always welcome for the Tax Review and those who would like to contribute should contact me please:

E-mail: [email protected]