Overview

Offshore trusts have become a key feature of family planning, with many families emigrating abroad and with others seeking to hold offshore value as a hedge against the rand. The purpose of this seminar is to discuss the basic tax implications of forming offshore trusts, generating offshore trust revenues and the subsequent uses of those funds by trust beneficiaries. Both tax and basic administrative impacts will be addressed.

Course Content

Introduction

• Settlement of an offshore trust: Cost considerations, estate planning, concerted attack on high-net-worth individuals and common reporting standards
• Jurisdiction of the offshore trust
• Beneficiaries

Establishment of trust and funding

• Exchange control considerations relating to the settlement of an offshore trust
• Tax considerations relating to the settlement and funding of an offshore trust
• Place of effective management of an offshore trust
• Loans to an offshore trust and the application of section 7C, section 7(8) and section 31 of the Income Tax Act

Acquisition and holding of assets by the offshore trust

• Exchange control and loop structure considerations
• Holding of investments directly by an offshore trust
• Holding of investments through interposed offshore companies, including controlled foreign company and place of effective management considerations
• Proposed tax law changes to the above
• Taxation of income from investments, trading income and capital gains in the hands of the offshore trust

Distribution of income and capital to South African tax and exchange control resident beneficiaries

• Repatriation of distributions back to South Africa for exchange control purposes
• Offshore accounting of income and capital receipts by an offshore trust
• South African tax implications of capital distributions from an offshore trust
• South African tax implications of income distributions from an offshore trust
• Tax return disclosure for South African tax resident beneficiaries

Presenter

Ruaan van Eeden

Event Investment

This webinar is not covered by any CPD subscription package

Non-member: R455

Company Price: R860

Payments & Cancellations

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