New queries, issue 4610

Land gift

Tax treatment of UK land sale for Portuguese resident.

An English father gifts his daughter a percentage of agricultural land through a bare trust of which he is a beneficiary. Four months later it is sold with planning permission for building development with a substantial capital gain. The daughter has been a Portuguese tax resident for three years. What is her situation regarding paying tax on the land?

I look forward to receiving Taxation readers’ assistance on this matter.

Query 19 028– Madeira.

Large accumulation

The tax implications of a substantial accrual of undistributed trust income.

In 1990 an offshore discretionary trust was set up by a non-UK domiciliary. The terms are that the trustees are to hold the income on trust to pay or apply it for the maintenance education support or otherwise for the benefit of the beneficiaries in...