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18 October 2011 / Malcolm Gunn
Issue: 4326 / Categories: Comment & Analysis , Trusts
MALCOLM GUNN considers the alternatives for those who set up non-resident trusts before 1998


  • Offshore trusts may have been set up for good reasons.
  • High administrative charges and harsh tax liabilities may now arise.
  • Dealing with stockpiled gains and TCGA 1992 Sch 4C.
  • Ensuring loss relief can be used against other gains.
  • The tax consequences of returning the trust to the UK.

I am told that a farmer once posted a sign at the edge of his field reading: ‘The farmer lets walkers freely cross this field but the bull charges’. My guess is that he was not too troubled by the hiking community once the sign was put up.

It is...

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