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Out of the frying pan...

25 July 2007
Issue: 4118 / Categories: Forum & Feedback

A few weeks ago, having finished our discussion about my clients' business accounts, I enquired whether they had given any thought to IHT mitigation. The client and his wife both have capital and income in excess of their needs and are higher-rate taxpayers. Their daughter is resident abroad, but is UK domiciled. She owns several properties, some of which are mortgaged, and also equities. It is beneficial for her to forego her personal allowance to avoid paying higher rate tax on her dividends.

A few weeks ago having finished our discussion about my clients' business accounts I enquired whether they had given any thought to IHT mitigation. The client and his wife both have capital and income in excess of their needs and are higher-rate taxpayers. Their daughter is resident abroad but is UK domiciled. She owns several properties some of which are mortgaged and also equities. It is beneficial for her to forego her personal allowance to avoid paying higher rate tax on her dividends.
The parents have made regular gifts out of surplus income and have also paid professional fees re the properties. The daughter's surplus income is remitted to a deposit account offshore. I thought no more about the matter until I read recent articles in Taxation about transfers abroad and offshore trusts.
When making the gifts the parents did not intend to avoid tax ...

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