Transfers of Assets Abroad (TOAA) Post-Fisher - Structuring, Risk & Litigation

Introduction

Designed for tax advisors and legal professionals, this new live and interactive session offers a deep dive into the landmark Fisher decision (2024) and its implications for Transfers of Assets Abroad (TOAA).

It will examine how Fisher redefines key aspects of TOAA, with a particular focus on identifying the transferor and explore the practical and strategic considerations arising from the case.

Barrister Shanzé Shah of Old Square Tax Chambers will offer an insight into the post-Fisher landscape, covering structuring options, risk management and the evolving litigation outlook, equipping participants to navigate challenges and seize opportunities in cross-border planning.

This session is an ideal follow-on for those who have attended Transfers of Assets Abroad (TOAA) - Recent Developments & Strategic Considerations

What You Will Learn

This live and interactive session will cover the following:

• TOAA Framework
• A concise review of the core principles, statutory provision and common traps under TOAA
• Fisher - Defining the Transferor
• The impact of the Fisher decision on identifying the transferor and the implications for liability and planning
• Post-Fisher Structuring Considerations
• Practical strategies and structuring considerations in light of recent judicial guidance to mitigate TOAA exposure
• Emerging Issues and Related Cases
• An examination of Moran and other relevant decisions highlighting potential risk areas and interpretative trends following Fisher
• Risk Management and Litigation Outlook
• Areas of potential challenge, dispute trends and key points of contention for practitioners advising on cross-border asset transfers in the current TOAA environment

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.