1. Choosing an Asset Holding Vehicle 23 rd Annual Transcontinental Trusts 2008 Supplemental Material

2. 2 Cellular Approach Tax Planning Avoids CFC or “close company” and tax attribution General UK Rule, five or few people must control more than 50% of the company/vehicle, such that multiple cells avoids this Compare and contrast with mutual/unit trust (open ended investment company)

3. 3 Private Trust Companies (old style) Private Trust Company Professional Directors/Trust Company [S70 liability acceptable] Advisory Panel Family/Advisers [S70 liability not acceptable] Trust Charity Guarantee Company Family/Adviser

4. 4 Private Trust Companies (new style) Private Trust Company Family/Advisors on board Professional management Trust Purpose Trust or Guarantee Companies

5. 5 Mobile International Pension Plans Who and Why? Expatriates/tax-free build up UK/EU top-up schemes (no tax relief) “International” companies (mobile executives) Corporate schemes Satellite schemes Key executives Future spin off

6. 6 Mobile International Pension Plans Contributor RAT = Trust/Insurance Contract Beneficiaries (eg contributor and family Guernsey resident professional Trust/Insurer Assets Cash Investments PropertyLoans Other Guernsey Personal Pension Schemes (Retirement Annuity Trust Scheme) (Section 40(ee)) (PCC/ICC)

7. 7 Captive Insurance Independent Insurance Co PCC Parent/ Customer Rented Cell “A” Rented Cell “B” Rented Cell “C” Etc Rented/ Owned 100% Premium Insure main corporate risks Insure excess Investment Pool Rent a Captive (PCC/ICC)

8. 8 Partnership  Joint and general liability variations Scotland and England Traditional professional businesses LLP’s are not preferred (restriction of personal liability)

9. 9 Limited Partnership General liability rests with GP Investors liability is limited For tax is transparent General Partner  Manager Investor

10. 10 Family Limited Partnership GP = Parent with control rights LP = Child with restricted and protected interests  GP  LP Family Business

11. 11 Family Limited Partnership (Cont’d) Uses include advantages for: Limiting control/transfer rights Succession planning Estate protection (transferring value of company to next generation at a discount) LP creditor protection

12. 12 Contact Details and Reference Sites Speaker’s Details Paul ChristopherMichael Betley PartnerManaging Director OzannesTrust Corporation of PO Box 186the Channel Islands Ltd 1 Le Marchant StreetPO Box 665 St Peter PortRoseneath, The Grange GuernseySt Peter Port, Guernsey GY1 4HPGY1 3SJ Website: www.ozannes.comWebsite: www.trustcorpci.com

13. 13 Contact Details and Reference Sites Other useful Guernsey websites Organisation/BodyWebsite Channel Islands Stock Exchangewww.cisx.com Guernsey Barwww.guernseybar.com Guernsey Directorywww.allaboutguernsey.com Guernsey Financial Services Commissionwww.gfsc.gg Guernsey Society of Chartered and Certified Accountantswww.gscca.guernseyci.com Income Tax Officewww.tax.gov.gg ITPAwww.itpa.org States of Guernsey (Government site)www.gov.gg The Law Officerswww.gov.gg/law