Leaked documents from Appleby show that Sassoon and several family members have been beneficiaries of a Cayman Island trust fund called the DCR Herschorn Settlement, established by Sassoon’s grandmother decades ago. Information from the files indicate that it was originally operating under Bahamian law. Documents state that the trust owns Orchard Limited, an investment holding company listed as residing in the Bahamas. In 2002, Orchard held $124 million, according to financial statements. By April 2007, its holdings had nearly doubled to $236 million, and that year, Orchard distributed $8 million to beneficiaries, according to the records.
By 2002, the trust had retained the global accounting firm Deloitte to advise it on tax matters. A 2008 fax from James Sassoon’s father, Hugh, to an Appleby administrator showed that Deloitte warned that U.K. taxpayers could be liable for U.K. taxes on more than $14 million of the trust’s funds in the case of a withdrawal. Hugh Sassoon also told the Appleby representative that he was forwarding the tax memo to two Orchard Limited administrators and that “no doubt you will discuss it with them.”
Sassoon said that the DCR Herschorn Settlement was established by his grandmother about 60 years ago for multiple family beneficiaries, including potential beneficiaries who were not necessarily U.K. residents. It held non-U.K. assets which were contributed only by his grandmother, who was not subject to U.K. taxes and who died more than 40 years ago. Because of the non-UK nature of the trust’s origin and assets, Sassoon said that there “is no question of assets having been 'moved offshore.'”
The creation of the settlement and its management company were disclosed to U.K. tax authorities and annual accounts have been sent to them as well, he said.
“Where U.K. domiciled individuals have received any benefit from the settlement, that has been disclosed in the normal way and any tax due has been paid. I have not received any benefit from the trust for more than 25 years,” said Sassoon. He also said that he disclosed his potential interest in the trust when he joined the Treasury in 2002, consistent with the Treasury’s disclosure rules.
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