This introductory course is for tax professionals who deal with international tax law on a regular basis and who need to understand the specific taxation issues raised by private and family trusts; its aim is to give the participants a framework within which to approach trusts and their taxation. The first day explains the trust concept and the way in which it is developing in modern trust jurisdictions. Part of the first day will be spent on case studies based on the creation and development of typical family trusts; the course participants will examine some examples of real trust documents in order to become familiar with their structure and language.

The second day starts with an examination of the taxation issues raised by private trusts, in order to give the course participants an awareness of these issues generally and to reinforce what was learnt on the first day about the trust concept. On the afternoon of the second day we move to jurisdictions that do not know the trust concept in their domestic law. This session covers both the legal institutions of those jurisdictions that are comparable with trusts, and the difficulties faced by those jurisdictions in dealing with trusts. The tax problems raised by trusts in these jurisdictions, and some of the responses in these jurisdictions, will be covered at the start of the third day.

Most of the third day will be devoted to case studies about cross-border trust situations. The course participants will apply the insights they have gained in the course so far to identify the issues arising in some common cases. Specific aspects of these situations will then be selected for more detailed study, including the application of double taxation treaties (both income tax treaties and gift/inheritance/estate tax treaties) to trusts.

The focus throughout the course will be on the structural problems that may arise, but some specific country detail will be examined in order to illustrate the issues. Participants will leave the course with the confidence that they can identify the issues, ask the right questions and analyze the tax systems of unfamiliar countries in respect of trusts. Course participants are expected to have a basic understanding of the principles of income taxation of at least one country, and a basic understanding of double taxation treaties. The number of course participants is limited to 30, to allow an interactive style of teaching. 

This course is supported by the Society of Trust and Estate Practitioners (STEP), a respected worldwide organization that counts many leading experts on trusts and taxation among its members. Some of the instructors on the course are prominent STEP members, enabling the course participants to benefit from their practical experience.