This Issue covers several areas within tax. First, we cover the UK tax implications of making a charitable gift to a non-UK charity and the pitfalls associated with such a step. Next, we discuss the long-awaited conclusion of the Fisher dispute and the Supreme Court's decision in favour of the individual taxpayers on the transfer of asset abroad rules. US persons will find our article on the US-UK Estate and Gift Tax Treaty relevant, particularly on how the Treaty could provide a hedge for US persons in the event of the abolition of the 'non-dom' regime. We consider the recent cases of Olivia Wilkinson & Ors v HMRC and Delinian Ltd (Formerly Euromoney) v HMRC and the application of the tax avoidance "main purpose" test to specific transactional arrangements. We review the implications of "good" and "bad" leaver provisions in the context of employment terminations. The complexities and pitfalls of "free of tax" legacies in wills, as well as new legislation impacting the Register of Overseas Entities, are dealt with in separate articles. Lastly, we discuss the Suterwalla and another v HMRC, in which the First Tier Tribunal grappled with a complex "mixed-use" scenario.
As we approach the end of another year, we would like to take a moment to extend our warmest wishes to all our readers, their families and extended network. We are mindful that it has been a challenging year for many and hope that the coming year brings peace, strength and happiness.
Thank you for your continued support and readership. We look forward to bringing you more insights into tax issues in 2024.