·       In my forthcoming two-part article for Taxation (Tolley), I discuss the operation of the Cultural Gifts Scheme (‘CGS’), FA 2012, Sch 14.
·       CGS exists to encourage ‘lifetime’ giving of pre-eminent items to museums and other public cultural institutions in return for a reduction in the donor’s tax liability.
·       An individual with a liability to Income Tax, CGT, and a company with a liability to Corporation Tax, can all benefit under the scheme.
·       In the essay I am currently writing for the Diploma in Art Law course – ‘Mediating Cultural Property Disputes’, one of the ‘Ethical Principles’ I advance is the existence of a custodial duty to preserve and protect cultural property.
·       I argue that this is a quintessentially a ‘fiduciary’ duty. 
·       The underlying premise is that every civilized society is a ‘fiduciary of humanity’, and so are their governments.
·       This is derived from classical theory about ‘Fiduciary Government’, which I apply to the policies and practice by Governments of institutional global governance through e.g. the agency of UNESCO.
·       Under International Law, there is a relationship between the ‘human environment’, ‘development’ and ‘culture’, see my blog, ‘Cultural Heritage Diplomacy/Mediation as a geopolitical tool of environmental protection’ on the ‘Geopolitical Mediation’ page at www.diplomaticlawguide.com.  See also my draft Article – ‘Transforming Conflict Through Humanitarian Mediation & Cultural Heritage Diplomacy’, on the ‘Geopolitical Challenges’ page.
·       I wonder – could the UK Government demonstrate global environmental leadership by establishing a fund to e.g. finance the purchase, replanting and restoration of tracts of the Amazon Rainforest, by:
–        Securitising the underlying proprietary interest in the land purchased, and potential revenue streams e.g. from licensing research about plants growing in the Rainforest, which may result in the development and sale of new pharmaceutical products worldwide.
–        Selling those financial instruments, i.e. ‘certificates’ to investors who:
(i) if an individual, could either offset the market capital value of the ‘instruments’ against a future tax liability, including IHT by transfering the instruments back to the issuer in exchange for a tax benefit (i.e. so the instruments would act as a ‘hedge’ against future IHT), or sell them to another investor i.e. in a secondary market; or
(ii) if a company/pension fund – obtain carbon credits in exchange for the capital invested.
Could this idea be developed to source and obtain financing for other environmental projects in the UK, or anywhere in the world?
Could an ‘ethical’ Islamic Finance ‘Sukuk’ be developed based upon this idea?