Taxation of Trusts and Global Wealth

The taxation of wealth and the use of trusts to reduce the tax liabilities of the wealthiest has come to the forefront of public debate in recent years, and the COVID-19 pandemic has only sharpened this focus. This course explores these issues in two halves. The first covers domestic UK issues including (a) UK capital taxes, particularly Inheritance Tax and Capital Gains Tax, and their application to trusts; and (b) the UK’s general responses to statutory interpretation and tax avoidance. The second half is taught alongside students on the MSc in Taxation across two intensive weekends either side of the Easter vacation. It covers international issues, such as (c) the taxation of foreign domiciled individuals and their trusts generally; (d) connecting UK tax factors including situs of assets and residence and (e) the use of foreign entities including trusts in succession planning where wealth is spread geographically and there may be conflict of law issues to consider.

Candidates will not be examined on the details of the Finance Bill or Act of the year of examination. Candidates are advised not to offer this paper unless they have studied the law of Trusts in their first law degree course.

These two elements are assessed separately. The domestic half of the course is assessed by way of an examination, while the international material is assessed by way of a submission.

This course requires attendance at 2 X weekends of teaching (i.e. 4 days total) which normally take place in Hilary term.