Offshore Tax

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       “The only conference I have found where I

                                                                                                                Registered Delegates
          have learnt plenty of new concepts”                                                         Receive a Memorandum on the
                                                                                                            New Remittance Basis of
                               (T. Pay, Greenback Alan LLP)

                             IBC's 27th Annual

Offshore Tax Planning
                        Latest Ideas for Individuals, Trusts & Companies
                                            Hear From Renowned Offshore Tax Experts:

                                                              Patrick Soares
                                                      GRAY’S INN TAX CHAMBERS
                      Giles Clarke, Author                                            Emma Chamberlain
                   OFFSHORE TAX PLANNING                                          PUMP COURT TAX CHAMBERS

                             John Rimmer                                                  John Cooney
                               APPLEBY                                                  ERNST & YOUNG

                             21 Brand New Cutting-Edge Topics Covered, Including:
 ❖ Clarke’s favourite remittance planning ideas                         ❖ Using the islands for UK property dealing
 ❖ Non-doms owning UK houses – strategic capital                          transactions latest developments
   payments                                                             ❖ Update on EBTs, QROPS and PPBs
 ❖ Non-doms owning UK houses – IHT shelter                              ❖ Magical offshore loan structures
 ❖ International image rights planning                                  ❖ Suspended estate administration planning
 ❖ International royalty planning                                       ❖ Why offshore EFURBS are thriving and are now a
 ❖ Vital estate planning for non doms who are or are                      must
   about to be deemed domicile in the UK                                ❖ New products from the islands and unmissable
 ❖ The hidden POAT dangers in non-resident structures                     Rimmer’s round up
 ❖ Dealing with HMRC6 (residence and ordinary                           ❖ Uses of USA LLCs
   residence) in practice                                               ❖ Exciting uses of overseas partnerships for non-doms
 ❖ Exciting defences against transfer of assets abroad -                ❖ Washing gains at the
   the legislation and the settlement code s.720 and                      lower rate in overseas
   s.731 etc.                                                             structures                            Register
 ❖ The offshore “Thin” unit trusts for UK land holdings                 ❖ Take a deep breath: How                          by
                                                                                                            10th Sep
 ❖ Using double tax treaties for overseas service                         overseas trusts are taxed                     tember
   agreements protection                                                  with date lines                          2010
                                                                                                              SAVE £50
 14th October 2010, Crowne Plaza Hotel - The City, London

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Register Today: Call: +44 (0) 20 7017 7790 Fax: +44 (0)20 7017 7824 E-Mail:
                        For Latest Programme or To Register:
“Access to the latest and greatest tax planning ideas”
(G. Fox, Francis Clark)

0900 Registration & Coffee
                                                                            1040 SESSION 5
0930 SESSION 1
                                                                            INTERNATIONAL ROYALTY PLANNING
                                                                            •   Planning for royalties as part of an overall IP strategy
                                                                            •   Moving IP offshore
•   Keep capital down
                                                                            •   Where to locate
•   Trusts' over outright ownership
                                                                            •   Witholding taxes... on what
•   The risks' and rewards' of gifts
                                                                            •   Thoughts on capitalising value
•   Pre 6th April 2008 income as clean capital
                                                                            John Cooney, ERNST & YOUNG
•   Remittance and reporting funds
Giles Clarke, Author, Offshore Tax Planning
                                                                            1100 Coffee

1000 SESSION 2
                                                                            1120 SESSION 6
THE ART PLAN I                                                              ARE OR ARE ABOUT TO BE DEEMED DOMICILE
•   Trust over company                                                      IN THE UK
•   Strategic capital payments                                              • Counting the years properly for deemed domicile
•   One year gap                                                            • Exclusions and exceptions for foreign domiciliaries
•   No deemed emoluments                                                    • Forced succesison rights
•   No IHT                                                                  • Evidencing and testing foreign domicile - traps to avoid
Patrick C Soares,
                                                                            • Excluded property trust traps for the foreign dom-
                                                                              resettlements, exclusions and other problems
                                                                            • Reservation of benefit problems for the foreign dom
Giles Clarke, Author, Offshore Tax Planning
                                                                            Emma Chamberlain, PUMP COURT TAX CHAMBERS

1010 SESSION 3
                                                                            1145 SESSION 7
                                                                            THE HIDDEN POAT DANGERS IN NON-RESIDENT
•   OPP “buyout” of capital payments
                                                                            • The foreign dom and POAT - three difficulties
•   IHT shelter
                                                                            • Making the election
•   No deemed emolument
                                                                            • Loans to and from foreign doms - s103 issues;
•   New Implications of CGT Regime -                                          ensuring deductibility against the correct asset
    22nd June 2010
                                                                            • Other problems on loans
Patrick C Soares,
GRAY’S INN TAX CHAMBERS                                                     Emma Chamberlain, PUMP COURT TAX CHAMBERS
Giles Clarke, Author, Offshore Tax Planning                                 1205 SESSION 8
                                                                            DEALING WITH HMRC6 (RESIDENCE AND
1020 SESSION 4                                                              ORDINARY RESIDENCE) IN PRACTICE (SPECIAL
INTERNATIONAL IMAGE RIGHTS PLANNING                                         FOCUS)
•   Characterisation of income                                              •   Overseas service contract trip wire
•   Case law background                                                     •   Emergency UK Visits
•   HMRC approach                                                           •   Devastating visits to the UK
•   Practical points                                                        •   Business visits to UK
•   Where to locate                                                         •   The accommodation problem
•   Some thoughts on the concept of "safe harbour"                          •   The acid tests
    percentages                                                             •   What Davis really meant
John Cooney, ERNST & YOUNG                                                  •   “Distinct break”
                                                                            •   Three case studies
    Send in Your Questions:                                                 Patrick C Soares, GRAY’S INN TAX CHAMBERS
    Please send in your questions in advance and Patrick Soares and IBC
    will integrate them into the programme so you get all your answers at   Emma Chamberlain, PUMP COURT TAX CHAMBERS
    the conference.
    Please contact Jonathan Olver +44 (0)20 7017 7247
    or email

                          To register please Call: +44 (0) 20 7017 7790                                                        Fax: +44
ore Tax Planning
   1225 SESSION 9                                     1445 SESSION 14
                                                                                      14th October 2010, Crowne

   ASSETS ABROAD LEGISLATION AND THE                  • Loans from overseas EBT’s - PAYE and NIC
   SETTLEMENT CODE – S.720 AND S.731 ETC              • Loans to participators – “triangle
   • ‘The Potter Defence’ – Vestey                      route”
   • Two (not just one) HMRC hurdles for associated   • Wholly tax free loans
     operations.                                      • Disregarded income; the company
   • Why the EU defence works                           approach
   • Plumming the depths                              • Overseas situs speciality debts
                                                      • Loans as the ultimate answer
   1240 SESSION 10                                    • The “golden DDS” – Precedent Included
   •   Why these are a must                           1500 SESSION 15
   •   SDLT                                           SUSPENDED ESTATE ADMINISTRATION
   •   FA 2003 s.75A                                  PLANNING
   •   Interest relief and capital allowances         • Tax free exemptions for UK estates –
   •   Precedent Deed included                          don’t complete the administration
   Patrick C Soares, GRAY’S INN TAX CHAMBERS          • Ensuring excluded property relief
                                                      • Partnership incorporation
   1300 Lunch                                         • SDLT exemption
                                                      Patrick C Soares, GRAY’S INN TAX CHAMBERS
   1400 SESSION 11
   •   The “easy way out”                             ARE NOW A MUST
   •   The directorship trap                          •   New restrictions on registered scheme
   •   Employment contracts                           •   Gross funds
   •   Sample treaties                                •   Ultimate deduction
   Patrick C Soares,                                  •   IHT free
   GRAY’S INN TAX CHAMBERS                            •   Comparative table
                                                      Patrick C Soares, GRAY’S INN TAX CHAMBERS
   1410 SESSION 12
   USING THE ISLANDS FOR UK PROPERTY                  1530 Tea
   DEVELOPMENTS                                       1550 SESSION 17
   •   Double share structures                        NEW PRODUCTS FROM THE ISLANDS AND
   •   Avoiding the building site problem             UNMISSABLE RIMMER’S ROUND UP
   •   Selling frozen options                         • Rise of the foundation
   •   Thinking capital                               • What else is new? Other alternative vehicles
   Patrick C Soares, GRAY’S INN TAX CHAMBERS          • Zero 10 (if, where and when?)
                                                      • Legislative outlook from the Islands
   1425 SESSION 13                                    • Latest trust cases from where it's all
   UPDATE ON EBTS, QROPS AND PPB’S                    happening
   • Guernsey QROPS                                   John Rimmer, APPLEBY
   • Malta QROPS
                                                      1620 SESSION 18
   • QROPS – investing back into the UK               USES OF USA LLCS
   • EBTS and HMAS cheap loans                        • Act Swiftly
     “surrender”                                      • Vital Drafting
   • PPB, trusts and companies following Willoughby   • Ownership extra “the body corporation – the UK LLP
   Patrick C Soares, GRAY’S INN TAX CHAMBERS            problem
                                                      Patrick C Soares, GRAY’S INN TAX CHAMBERS

4 (0)20 7017 7824                       E-Mail:                         For Latest
                                                                    “Exceptional breadth of topics and consistent speakers”
                                                                                                                          (S. Lewin, Bircham Dyson Bell)
Plaza Hotel - The City, London
     1630 SESSION 19
     FOR NON-DOMS                                                              Patrick Soares, GRAY'S INN TAX CHAMBERS
     • The C&M test                                                            Patrick Soares practices at Gray’s Inn Tax Chambers, specialising
     • The “future”                                                            in tax and trust work. He is the author of Offshore Investment in
     • Getting overseas income outside                                         UK Land: Tax Efficient Structures and Non-Resident Trusts.
       the net                                                                 Recent cases include acting for the Mauritius revenue in Lutchmun
     • Why a partnership is a must                                             v Director General Mauritius Revenue Authority (Prive counsel)
     Patrick C Soares, GRAY’S INN TAX CHAMBERS
                                                                               and the tax payer in Underwood v HMRC (court of appeal)

     1640 SESSION 20                                                           Giles Clarke, Author, OFFSHORE TAX PLANNING
     WASHING GAINS AT THE LOWER RATE IN                                        Giles Clarke is author of Offshore Tax Planning (16th edition,
     OVERSEAS STRUCTURES                                                       2009) and general editor of Spitz and Clarke: Offshore Service.
     • Unconditional contracts
                                                                               John Rimmer, APPLEBY
     • Underwood v HMRC
                                                                               John Rimmer is a partner in the Isle of Man office of leading
     • Jerome v Kelly                                                          international offshore law firm Appleby. He advises individuals
     Patrick C Soares, GRAY’S INN TAX CHAMBERS
                                                                               and trust companies on all matters concerning trusts, wills,
                                                                               succession and probate. He is chairman of the Isle of Man branch
     1650 SESSION 21
                                                                               of STEP, as well as a member of ACTAPS. He qualified as a
                                                                               solicitor in England and practised in London before re-qualifying
                                                                               in the Isle of Man.
     Detailed Memorandum-a must for all those involved in this
     area                                                                      John Cooney, ERNST & YOUNG
     • 1998                                                                    John Cooney is Partner in E&Y’s Entertainment Group and has
     • Stockpiled gains                                                        over 25 years of experience of advising on tax effective structuring
     • The 10% per annum increase income in underlying                         and planning across the media sector, both locally and on an
       companies                                                               international scale. His team works with a number of
     • 1991                                                                    internationally renowned musicians and recording Artists carrying
     • Very old gains and attribution-When were they tax free?                 out a comprehensive range of services including tax planning,
     • 2008                                                                    compliance and accounting. The team also acts for individuals
     • Old Vestey income-where is it?                                          involved in the film, publishing and sporting sectors as well as the
     • Post Vestey income                                                      executives of major media organisations. The team carries out
     • Safe Leedale gains-where are they?                                      valuations of IP, provides estate planning advice, deal planning
     • Detailed chart Provided                                                 and a host of other one off assignments.
     Patrick C Soares, GRAY’S INN TAX CHAMBERS
                                                                               Emma Chamberlain, PUMP COURT TAX CHAMBERS
                                                                               Emma Chamberlain Fellow of Chartered Institute of
     1710     Close of Conference
                                                                               Taxation–was for some years a solicitor before being called to the
                                                                               Bar in 1998. She now practices at Pump Court Tax Chambers
                                                                               after leaving 5 Stone Buildings in November 2009. She
                                                                               specialises in onshore and offshore tax and trust work for private
                                                                               clients. She is a member of STEP and sits on their Technical

      Sponsorship Opportunities                                                Committee. She was chair of the Chartered Institute of Taxation
                                                                               (CIOT) Succession Taxes Sub-Committee for over 4 years until
      This event regularly attracts a wide spectrum of Lawyers, Accountants,
      Tax Advisers, Trust Companies, Private Banks and Fiduciaries.            May 2009. She is co-editor of Dymond’s Capital Taxes; co-author
      If you are interested in accessing a senior level audience at this       of Pre-Owned Assets and Capital Tax Planning Strategies 2nd
      cutting edge industry forum, we can work together to identify creative
                                                                               edition published December 2005 and Inheritance tax planning:
      solutions through a variety of means:
                                                                               what to do before 6th April 2008 January 2008 and co-author of
      •    Hosting a networking drinks reception
      •    Booking an exhibition space at the conference                       Trust Taxation 2nd Edition published Dec 2008 all published by
      •    Advertising in the delegate documentation pack                      Sweet and Maxwell. She is a co-author of Revenue Law
      Please contact David Gold +44 (0)20 7017 7243                            published by Tottel.
      or email

t Programme or To Register:
                                                                                              In conjunction with
                                                                                              Patrick Soares
                                                                                             GRAY’S INN TAX

                         Offshore Tax Planning
                       Latest Ideas for Individuals, Trusts & Companies
                                                       14th October 2010, Crowne Plaza Hotel - The City, London
        Dear Tax Practitioner,

        This promises to be one of the most exciting conferences of the year bringing practitioners fully up to
        date with what is happening in the offshore world and tax planning.

           For instance this conference will go through the most important insights from the emergency
        budget including:

        • A review of non domiciled individuals taxation & the recent political undercurrents
        • The CGT rate increase & what will it mean to the offshore community
        • The update on the new remittance basis of assessment

           Fear not however, because help is at hand, in the form of IBC’s 27th annual Offshore Tax
        Planning conference.

            A leading panel of specialists will
         guide you through this essential area
                                                                  “Another vital step forwards
             of practice – these include:
                                                               through the maze of Offshore Tax
               Emma Chamberlain                                           Planning"
                                                                              (Z. Wilamowski, Hamels)
                  Giles Clarke
                 John Rimmer                                   "Excellent presentations & quality
                 John Cooney                                                speakers"

                                                                            (S. Marsden, Magister Law)

                    Receive over 300 pages of Offshore Tax Planning Structures

           The above speakers will provide you with detailed notes on the topics they will be covering. Whereby
        you will collect an essential booklet with over 300 pages of the very latest offshore tax planning tips.

           In short it will be potentially an explosive day! But most certainly it will be an exciting day and very,
        very informative.

           We look forward to seeing you in October 2010.

        Kind regards                                                                         Register
                                                                                          10th Sep
                                                                                           SAVE £5
        Patrick C Soares, GRAY’S INN TAX CHAMBERS

           Register Today: Call: +44 (0) 20 7017 7790 Fax: +44 (0)20 7017 7824
E-Mail:          For Latest Programme or To Register:
Offshore Tax Planning                                                                                                                                                                                             KW5147
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