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An introduction to trusts

May 2008

The concept of a trust goes back to the time of the crusades and has evolved to become an integral part of wealth and tax planning around the globe.

A trust is a confidential legally binding agreement (almost always in writing) whereby the original owner of the assets (the settlor) transfers legal title of their assets to another (the trustee) who will hold these assets for the benefit of a defined class (the beneficiaries).

Principal characteristics of a trust

The crucial feature of a trust is that although legal title is passed to the trustee by the settlor, the trustee is obliged to look after the property transferred for the enjoyment and benefit of the beneficiaries. The trustee is a custodian who, other than charging a reasonable fee, cannot benefit personally from the trust assets. All the rights to the enjoyment of those assets belong to the beneficiaries, who have legal right to force the trustee to act in accordance with the terms of the trust instrument and the laws governing trusts, whilst realising that the trustees must never act illegally.

In today’s commercial world, it is more usual to engage professional trustees, such as Fairbairn Trust Limited, who must exercise a greater degree of diligence than would be expected from an individual trustee. Employing a professional firm provides settlors with reassurance and the peace of mind that the assets settled in trust will be administered competently and professionally in accordance with their long-term wishes, and always for the benefit of the beneficiaries.

Why set up a trust?

A trust is one of the most secure and flexible financial planning vehicles available, particularly when established offshore. Subject to the tax laws applicable to the settlor’s estate, a trust may enable a settlor to make long-term plans for the preservation or distribution of wealth, during or after their lifetime, in precisely the manner required. By transferring property into trust, settlors can ensure that the management of that property will not be interrupted on their death by probate or other formalities, but continue in accordance with the trust instrument and their letter of wishes.

A trust may also be an effective tax-planning tool, for example, in respect of estate or inheritance taxes on assets situated outside the country of the settlor’s nationality. It may also provide complete confidentiality and protect assets from the imposition of exchange controls or similar political measures as well as providing a means of protecting assets from risk of unforeseen financial difficulty.

Taxation - By establishing certain types of trusts, individuals may remove assets from their estates thereby reducing their taxable wealth and limiting exposure to income tax, capital gains tax, wealth tax, gift tax and inheritance tax.

Asset protection - Having worked so hard to build a valuable business or asset base, it is everyone’s right to try to preserve that wealth for themselves and their family. A trustee resident in another jurisdiction may act as guardian of a family’s wealth thus offering a greater level of protection over those assets. This may be of particular interest to settlors living in politically sensitive areas where their wealth could be at risk. Assets in a trust may be protected from the imposition of exchange controls or other government regulations, and once removed from an estate free the settlor from the threat of confiscation or devaluation.

By passing legal ownership of trust property to trustees, the name of the settlor is removed from title deeds and other documents of ownership. A trust cannot be established to defeat or defraud creditors but, provided the settlor is solvent and expects to remain so, it is perfectly reasonable for a wealthy individual to hedge against the unexpected by establishing a trust.

Family matters -

  • Avoiding forced heirship - The law in some countries dictates to whom a person may leave their assets on death and in what proportions these may be left. If this is likely to be contrary to an individual’s wishes, they may consider transferring assets into a trust located in a common law jurisdiction such as Jersey, which accepts that a trust is valid, even if forced heirship issues may arise in the settlor’s country of nationality.
  • Minimising estate administration costs - The cost of probate upon the death of a wealthy individual can be high and even force the unwanted sale of assets. By establishing a trust, settlors may minimise the disruptive effects of their own death on the family estate. Settlors can therefore rest assured that their family will be looked after in the same way after their death as before in accordance with the terms of a trust established during their lifetime, and the wishes expressed to their trustees.
  • Protecting individuals - Certain family members may be less capable of managing their own affairs than others, or be adversely affected by the knowledge of their future inheritance. This might apply to infant children or aged parents, and professional trustees can be of great help in such circumstances.
  • Keeping the estate intact - Settlors may wish to ensure that, after their death, the wealth that they had accumulated is not immediately split up amongst their heirs but is maintained in one fund. Distributions may be made to family members whose needs dictate but the corpus of family wealth can be preserved for succeeding generations.

The advantage of offshore trustees

Not every person who wishes to establish a trust should assume that the trust should be offshore. However, there can be major benefits from going offshore and the following principal factors should be considered.

Taxation - Jersey is an ideal location for the establishment of an international asset holding trust. There are no capital taxes in Jersey such as gift, capital gains, wealth or estate taxes and for trusts which have no Jersey resident beneficiaries there are no income taxes. Thus capital can grow and income can accumulate within the trust free of all Jersey taxation.

Government interference - Settlors may wish to protect their estate from government interference such as the imposition of exchange controls. It is highly unlikely that an offshore centre like Jersey would ever introduce such controls.

Reporting requirements and confidentiality - There is no requirement for a Jersey trustee to disclose the names of the settlor or beneficiaries of a trust. Similarly, there is no requirement for a trust to be registered in Jersey or for any documents relating to the trust to be registered, stamped or made available for inspection. Consequently, a trust remains a private arrangement between the settlor and the trustee where confidentiality can be assured.