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Taxation of Offshore Entities (Taxation of trusts (IHT tax charges (Ten…

- - - - The assets of discretionary (and some other trusts) may give rise to IHT charges every 10 years and a charge when the property leaves the trust
      - To the extent that an excluded property holds non UK situs assets these charges will not arise
      - Offshore administrators should diarise the consideration of what steps may need to be taken prior to the 10 year anniversary of trusts under their administration to reduce the IHT charge that becomes payable
- - - - Instead each member is assessed for tax as if they were members of general partnership. They are treated as having carried on the activities of the LLP in proportion to their membership