United States | Publication | April 2022
The throwback tax is the US tax law’s main tool for discouraging tax-free accumulation of income by foreign non-grantor trusts for US beneficiaries. Its complex rules are a dangerous minefield that should be avoided. This article reviews the operation of the throwback tax rules, and assesses the effectiveness of this trust anti-deferral regime in various fact patterns. It also discusses how the trust anti-deferral regime interacts with the US law’s foreign corporation anti-deferral regime, another minefield.
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The Court of Appeal has overturned a 2023 High Court decision in Manolete v White [2024], ruling that courts cannot issue injunctions requiring members to draw down their occupational pensions to make them available to judgment creditors.
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The Chancellor presented her maiden Budget on October 30, 2024.
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On October 29, 2024, the PPF published a response to its March 2024 consultation, confirming that it would proceed with its proposal to give actuaries the option of using a bespoke discount rate assumption in s. 143 valuations of smaller pension schemes.
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