Private Client Series Presents:

13th Annual

th Reg & Oct ister SA ob b VE er y 2 20 00 13

11

Tax Planning for Non-Domiciliaries

Key programme highlights include: v Preserving clean capital after the 2008 rules v Domicile and its continued relevance v Impact of the GAAR on resident non-doms v ATED v Advantages of becoming a resident v Inheritance tax and the conflict of laws
YOUR PANEL OF SPEAKERS FOR 2013 INCLUDE:
n Michael Sherry, Barrister, TEMPLE TAX CHAMBERS n Jonathan Burt, Partner, Private Client, HARCUS SINCLAIR n John Barnett, Partner, BURGES SALMON & Formally GAAR Interim Panel Member n Jeremy Franks, Head of Wealth Planning Advisory, UBS n Oliver Court, Partner, MACFARLANES n Paul Stibbard, Executive Vice Chairman, ROTHSCHILD n Michael OSullivan, Barrister, 5 STONE BUILDINGS n Bart Peerless, Head of Private Client, CHARLES RUSSELL n Robin Mathew QC, Barrister, NEW SQUARE CHAMBERS n Richard Frimston, Partner & Head of Private Client, RUSSELL COOKE LLP n Anna Steward, Senior Counsel, Geneva, CHARLES RUSSELL n Julia Ramsden, Senior Associate, LAWRENCE GRAHAM

Plus
v  3 Key case studies on: - Prest and the corporate veil - Mal-administered trusts - Island quirks how to tell the difference v  Q&A session: What does the future hold for non-domiciles in 2014 and beyond

Good summary of the change to the taxation of non-domiciles over the course of the last year. Always very interesting and relevant.
Farrer & Co

Tuesday 10th December 2013

Organised by:
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Venue: Central London

.5

Register Today: Tel: +44 (0)20 7017 7790 Fax: +44 (0)20 7017 7824 E-Mail: kmregistration@informa.com For Latest Programme and To Register: www.ibc-events.com/NonDomTax

HOUR

13th Annual

Tax Planning for Nonto Preserving Clean Capital after the 2008 Rules

9.40  Approaches Dear Private Client Practitioner, Non-domiciles are creeping more and more into the public consciousness. An increasingly sharp political and regulatory focus has brought a plethora of change in recent years. Non-Domiciliaries are of key importance not only for private client tax advisers, but a also private banks and investment managers. For instance the Statutory Residence Test has arrived having come into force on 6th April 2013 and it will mean lengthy work for you as practitioners. In response to these changes and with the overall goal of preserving clean capital, IBC returns for the 13th year of the Tax Planning for Non-Domiciles conference. You will hear from a stellar panel of experts, well versed in dealing with non-domiciliaries, on how you can best advise this set of clients on the key topics. I look forward to welcoming you to the conference in December. Kind regards

 Non-domiciles key objective is tax efficient access to the UK market while preserving clean capital. This session will delve into how non-domiciles, since the dramatic overhaul in the Finance Act 2008 can reach this objective.  Finance Act 2012 - changes the scene?  Business investment relief  Using the reliefs in the way intended  Domicile status  Spouse exemption  GAAR and other anti-avoidance legislation

Jeremy Franks Head of Wealth Planning Advisory UBS

Oliver Court Partner MACFARLANES 10.20  Domicile

and its Continued Relevance

 Law of domicile and its relevance for tax, inheritance and matrimonial Law  Increasing importance of connecting factors  Impact of deemed domicile rules  Double tax treaties for estate taxes.

Paul Barford Senior Conference Producer IBC Global Conferences

Paul Stibbard Executive Vice Chairman ROTHSCHILD Julia Ramsden Senior Associate LAWRENCE GRAHAM

11.00 Refreshment Break 11.15  Impact

of the GAAR on Resident Non-Doms

9.00 9.30

Registration

Chairmans Opening Remarks

Jonathan Burt Partner, Private Client HARCUS SINCLAIR

The General Anti-Abuse rule (GAAR), introduced by  Finance Act 2013, promises to mark a sea-change in the way in which we do tax in the UK. It imposes an overriding statutory limit on the extent to which taxpayers can reduce their tax bills. Taxation is no longer to be regarded as a game where taxpayers can indulge in any ingenious scheme in order to save tax. That limit is reached when what is done goes beyond anything which could reasonably be regarded as reasonable. In this session, John Barnett who served on the interim GAAR panel will look at the impact of the GAAR on RNDs including:  Keep Calm and GAARy on: why RNDs have less to fear from the GAAR than might be thought

To register please Call: +44 (0)20 7017 7790 Fax: +44 (0)20 7017 7824 E-Mail: kmregistr

-Domiciliaries

10th December 2013, Central London

 The position of the self employed and employees  The use of trusts, both offshore and domestic, and companies  Remittance basis liability  Tax aspects of the purchase or occupation of accommodation  Possible Inheritance tax and capital gains tax problems  Enforcement of foreign taxes in the UK

 The Elephant Test: how do you judge what is reasonable?  A more in-depth look at HMRCs guidance  What the GAAR means for tax-advisors

Michael Sherry Barrister TEMPLE TAX CHAMBERS

John Barnett Partner BURGES SALMON & Formally GAAR Interim Panel Member 11.55

3.05 3.20

Robin Mathew QC Barrister NEW SQUARE CHAMBERS Refreshment Break  Inheritance

 Interaction with inheritance tax planning  Costs of funding the ATED  Structures when purchasing a new property  Re-structuring a current property  Buy-to-let  Reliefs  Commerciality of using companies

ATED

Jonathan Burt Partner, Private Client HARCUS SINCLAIR

 This session will consider the differing conflict of laws / private international law systems, their effect on successions, gifts and matrimonial property regimes and the consequences for inheritance and gift taxes. The session will cover the following questions:  Conflict of laws private international law: differing systems in the world and preliminary questions  Matrimonial property regimes  Succession law and anti-avoidance  Inheritance tax and double tax treaties  EU succession regulation No 650/2012

of Laws

Tax and the Conflict

12.35 Lunch 1.45

 Prest and the Corporate Veil - The corporate veil where do we stand now? - Why did the wife succeed in Prest -  What lessons can we learn from the decision as to future planning.  Mal-administered Trusts - Redress - Tax exposure - Profile / reputation  Island Quirks How to tell the Difference - Remedies - Defences and obstacles to claims - Jurisdictional considerations

3 Key Case Studies

Richard Frimston Partner & Head of Private Client RUSSELL COOKE LLP

4.00  Panel

Session: Where will we be in 5 Years?

 Political landscape  Future of the non-domicile rules  Investing into UK qualified businesses  Into the looking glass what might happen in the next Parliament?  Impact of Swiss/UK tax co-operation agreement  Son of FACTA

2.30

Michael OSullivan Barrister 5 STONE BUILDINGS  Advantages

 The operation of the new UK rules on residency will be considered. Emphasis will be on practical planning before UK residence is established by those who are not domiciled in the UK (and protection of that status in the long term).This session will also address potential pinch points or problems which may affect an individual newly resident in the UK including:

Resident

of Becoming a

Bart Peerless Head of Private Client CHARLES RUSSELL Jonathan Burt Partner, Private Client HARCUS SINCLAIR Anna Steward Senior Counsel, Geneva

4.40

CHARLES RUSSELL

Chairmans Summation

ration@informa.com For Latest Programme and To Register: www.ibc-events.com/NonDomTax

Tax Planning for Non-Domiciliaries

10th December 2013, London

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