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Pre-Owned Assets & Inheritance Tax Planning

Lexis Nexis Tolley Second Annual Conference, London, 23 February 2006

Reviewed by Mark McLaughlin CTA (Fellow) ATT TEP


An early start from Manchester to London (the alarm clock went off at 4.30am!), a snowy morning and delays on the flight from Manchester to Heathrow (which resulted in me arriving at the seminar 10 minutes late) could not dampen my enthusiasm to attend this conference (sad though that may seem to some!). Inheritance Tax (IHT) and Pre-Owned Asset Tax (POAT) are fairly ‘hot topics’ at present. The conference literature quoted that ‘70% more people will pay IHT by 2005’, so it is little wonder that the conference was well attended.


1) The Speakers

The speaker list was highly impressive. All are either well-known Tax Counsel or Tax Experts in their field. The conference was excellently chaired by John Tallon QC. His observations were insightful and at times light hearted. Mr Tallon kept the conference moving along to the timetable, and he also delivered a very interesting keynote address on ‘Planning for non-UK domiciled individuals’. The other speakers were Terry Jordan of BKL Tax, Nick Hughes of Chiltern plc, Jeremy Woolf, Barrister, Sarah Dunn, Barrister, both of Pump Court Tax Chambers, and Matthew Hutton, Chartered Tax Adviser. It would be unfair to single out particular speakers for praise, as in my view all of them delivered informative lectures with great skill.


2) The Conference Notes

The documentation package consisted of notes and copy slides. Incorporating images of the slides in the notes is a good idea in my view. It allows additional space for scribbling notes and thoughts during the lecture, and provides a helpful aide memoire after the event. The notes for each lecture were generally relatively short and concise. The quality of content will be invaluable, because the notes are written in practical terms and with the minimum amount of tax ‘jargon’. The technical content of the notes is very high, as one might expect from such eminent experts. Planning points are always very welcome for practitioners. Conference notes are very often esoteric, and finish up being filed or left on a shelf to gather dust. However, these notes are more likely to be read and used, because they are not theoretical but practical in nature.


3) The Conference Content

The conference subjects were as follows:

• Pre-owned assets tax planning;
• IHT and trust planning;
• Business property relief;
• Planning for non-UK domiciled individuals;
• Tax-efficient will planning; and
• Post-death planning, variations, discretionary trust appointments and disclaimers.

Clearly, subjects of this nature require the delegate to have a certain degree of prior knowledge in those areas. The technical level of this conference was high. It was not an ‘update’ type course of a general nature. The information and opinions of the speakers were ‘up-to-the minute’ in terms of explaining new developments and concepts in their particular areas. For example, pre-owned assets tax is still evolving in terms of policy and practice, and is relatively fast moving in terms of knowledge of the Revenue’s views on its application.

I hope that a publisher or the conference provider commissions me to write a technical review of this conference. It would be an excellent excuse to read the notes in greater depth, and to be able to report and comment on the practical and technical points and issues raised by the speakers.


4) The Venue

The venue was the Holiday Inn, Regent’s Park, London. It was a very pleasant venue for a seminar, as one might expect. The lunch was very palatable, too! A general observation (from someone who lives in Manchester) is that the best conferences normally seem to take place in London. It would be greatly appreciated (by the writer at least!) if Lexis Nexis and others could perhaps stage conferences of this quality in Northern England as well.


5) Overall

This was a well organised, informative, enlightening conference. I left with many excellent planning ideas in the areas covered. It was refreshing to attend a conference containing practical content, as opposed to mere statute and theory. There was a large volume of information to take in during the day, and further reading of the notes afterwards will be important to ensure that the ideas and concepts properly sink in.

The full cost of the conference was £599 plus VAT, although some discounts and concessions were available. This is not an inconsiderable amount. However, the cost does compare favourably with other conference providers, particularly those in which the speakers include Tax Counsel. The conference notes are separately available at £299 per pack.

Overall, this conference should be very useful to practitioners involved with inheritance tax planning. It is not the type of conference that will be attended to pick up CDP points (not by me, at least!). The writer would fully expect practitioners to be able to apply many of the planning points and insights from the conference in their day-to-day work, and that has to make the event very good value for money. However, getting up at 4.30am to attend is definitely not recommended!


More information

For full list of forthcoming conferences, please visit the Tax Calendar.


Disclaimer

The views expressed in this review are those of the writer only and not necessarily those of TaxationWeb. No responsibility can be accepted by the writer or TaxationWeb for any loss arising from action undertaken or refrained from as a result of this review.


Mark McLaughlin
February 2006

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