PRACTICAL TAX PLANNING 2024
42nd Annual Oxford Four-Silk Fourteen-Speaker Residential Seminar
Chair: Robert Venables K.C.
Date: 24/09/2024
Price: £1,325.00 + VAT
KEY HAVEN PUBLICATIONS LTD
PRACTICAL TAX PLANNING 2024
42nd Annual Oxford Four-Silk Fourteen-Speaker Residential Seminar
Tuesday September 24th - Thursday September 26th 2024
Merton College, Merton St, Oxford.
Full price £1,525 per delegate plus VAT (£305.00) = £1,830
SPECIAL EARLY BOOKING DISCOUNT
For bookings made and paid for before August 5th 2024
£1,325 per delegate + VAT (£265) = £1,590
(to include course notes, accommodation, meals and wines.)
SPEAKERS
Robert Venables K.C. (Chairman)
James Kessler K.C.
Rory Mullan K.C.
Philip Simpson K.C.
Sarah Squires
Harriet Brown
Ben Symons
Patrick Boch
Mary Ashley
Ross Birkbeck
Rebecca Sheldon
Shane O’Driscoll
Chris Vallis
Shanzé Shah
The speakers are all practising barristers. They are all members of Old Square Tax Chambers,15 Old Square, Lincoln’s Inn W2A 3UE: Website: www.taxchambers.com, Contact: clerks@15oldsquare.co.uk
PROVISIONAL TIMETABLE
TUESDAY September 24th
12.00 Arrival and Registration
13.00 Lunch Merton College
14.00 Chairman’s Introduction
14.10 What to do with Individuals' UK Real Property Portfolios - Ross Birkbeck
Long-Term Structures: Incorporation? Partnership ? Limited liability Partnership ? Use of IHT and CGT EBT provisions? - Tax Considerations and Risks"
14.50 Withholding tax post -Hargreaves Property Holdings - Sarah Squires
The obligation to withhold - yearly interest (Lehman Administrators/Hargreaves Property Holdings) - key exemptions: UK-UK and treaty relief - "beneficial entitlement" - other issues
15.30 Post-death variations to estates - Mary Ashley
Tax consequences – potential pitfalls – options where there are minor beneficiaries
16.10 Discussion Session with Refreshments
16.25 The Concept of Trading - Rebecca Sheldon
Fundamental principles and recent case law- When does a trade commence? - How it applies in distinct areas of tax which may come up for private clients: Income tax vs CGT treatment; Business property relief for IHT; Business asset disposal relief for CGT; Gift hold over relief for CGT; If a property trade is being carried out, the potential implications for principal private residence relief
17.05The remittance basis - Rory Mullan K.C.
What is left for the remittance basis after changes to the non-dom rules and the election? - Recent cases: Segal, D'Angelin and Alimahomed - Other issues
17.45 Estoppel by Convention within the Context of Tax Litigation - Christopher Vallis
What is it and how did it come about? - The test for estoppel by convention - The Tinkler decision - More recent tax decisions (York) - How might it be useful to taxpayers?
18.25 Approx Close of Formal Proceedings for the Day
19.00 Pre-dinner Drinks
19.30 Dinner in the Great Hall
WEDNESDAY SEPTEMBER 25th
09.30 Chairman’s Introduction
09.35 Partnerships, Limited Partnerships and Limited Liability Partnerships - Robert Venables K.C.
Non-tax law: distinctions in reality - HMRC myths. Distinctions in general tax treatment. Taxation of income: income tax treatment including current law on basis periods - corporation tax treatment of income - deemed partners - mixed partnership rules - income streams rules. Capital gains tax treatment - HMRC published confusion. Stamp duty land tax: special irrational rules for partnerships including property investment partnerships.
10.20 Employee Ownership Trusts - Philip Simpson K.C.
What is an employee ownership trust - When is an employee ownership trust a useful thing - What are the tax benefits - What conditions must be met - What are the tax traps
11.00 Discussion Session with Refreshments
11.20 Double Tax Agreements For UK Residents including Non-UK Domiciliaries - Harriet Brown
How treaties can take the sting out of changes to the taxation of non-UK domiciliaries - Treaty residence vs statutory residence test - DTT provisions for individuals: OECD Model - CDOT treaties with the UK (Gibraltar, Guernsey, Isle of Man and Jersey) - EU states: Cyprus, Greece, Ireland, Italy and Cyprus-UK treaties - US Treaty
12.00 - 12.45 Changes to UK non-dom rules – an Irish alternative? - Shane O’Driscoll
Introducing some of the Irish tax rules and tax considerations for the internationally mobile
13.00 Lunch
16.30 Discussion Session with Refreshments
16.45 The Unallowable Purpose (CTA 2009 Section 441) - Patrick Boch
The rule - Case law, including Kwik Fit and BlackRock Holdco 5 LLC - Application to increase of interest under an existing loan - Solutions
17.30 Civil law trust equivalents: usufruct, substitution fidéicommissaire, libéralité - James Kessler K.C.
UK tax treatment: IHT, IT, CGT; planning implications
18.15 Approx Close of Formal Proceedings for the Day
19.15 Pre dinner drinks
19.45 Gala Dinner Merton College (Black-Tie entirely Optional) in the Great Hall
THURSDAY SEPTEMBER 26th
09.30 Chairman’s Introduction
09.35 CGT roll-over relief on replacement of business assets - Shanzé Shah
Basics - Do the assets need to be used for the purposes of a trade? Does the taxpayer need to be carrying on a business? - Qualifying assets - what is meant by "occupied (as well as used) for the purposes of the trade"?
10.20 Offshore Trusts - Ben Symons
Correctly structuring loans to and from offshore trusts to minimise income tax and inheritance tax; the perils of the transfer of assets abroad provisions in relation to offshore trusts."
11.00 Discussion Session with Refreshments
11.15 Questions to Speakers
12.45 Lunch
14.00 Close of Seminar
**************************************************************************
REGISTRATION DETAILS
For application and conditions please contact:
Key Haven Publications Ltd, PO Box 669, Oxford OX3 3AU Tel: 01865 352121
E-mail: aw.khpplc@khpplc.co.uk
CANCELLATIONS:
Those confirmed in writing 30 days prior to the Seminar qualify for a full refund,
subject to a £250 administration fee. Cancellations within 30 days prior to the Seminar do not qualify for a refund, although substitutions will normally be allowed at Key Haven’s discretion, subject to a £100 administration fee.
www.khpplc.co.uk