Unpacking BCR080 - Tax implications for resident beneficiaries of a foreign pension trust
There has been a lot of discussion around the binding class ruling BCR080 that was issued by SARS on 12 August 2022. This ruling determines the income tax, capital gains tax and estate duty implications for resident beneficiaries of a foreign pension trust.
Rupert Worsdale will be discussing this ruling and giving us his valuable insight and views of some of the points raised by SARS.
Speaker: Rupert Worsdale TEP, Maitland, South Africa
Rupert has a broad-ranging practice, covering corporate tax, personal tax, trusts and investment funding. In the field of corporate tax, he advises corporations on how to structure cross-border acquisitions and how to optimise the structure of their existing international operations.
In the field of personal tax, he advises individuals on tax residence issues and tax planning issues. In the field of trusts, he advises clients on how to resolve problems with existing trust structures, the most appropriate structures for the preservation, enhancement and devolution of wealth and the use of trusts and other structures for commercial purposes.
In the field of investment funds, he advises clients on the tax structure of investment funds and how to resolve problems with existing fund structures. Although technically qualified in South Africa and the UK, Rupert has worked with the laws of, and the lawyers in, a wide variety of jurisdictions and specialises in finding the appropriate jurisdictions and structures to meet the client’s needs.
Email [email protected] by Monday 31 October 2022