Capital Gains Taxation of Non-Resident Settlements

Following the addition of 24 pages of anti-avoidance legislation to the Finance Act 1991, the capital gains tax advantages of non-resident settlements have been substantially changed. Five charges have been affected: the charge on disposals of settled interest, the emigration charge, the settlor charge, the capital payments charge and the supplementary charge. Dual resident, migrant and transferee settlements are also affected. This volume highlights the many anomalies present in the 1991 legislation, and illustrates their operations with over 60 examples. The author provides a detailed analysis of the new rules and explains their effects on both pre-and post-Budget day settlements, with tax planning strategies.