Download or read book Booth written by Denzil Davies and published by LexisNexis. This book was released on 2004-01-01 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt: This text explores the meaning of residence, ordinary residence and domicile as they relate to taxation. It discusses the tests which establish whether or not, for tax purposes, an individual, partnership, or trust is resident, ordinarily resident and/or domiciled in the UK.
Download or read book Booth and Schwarz Residence Domicile and UK Taxation written by Jonathan Schwarz and published by . This book was released on 2022 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This title gives the reader authoritative guidance on the legislation dealing with residence, principally the Statutory Residence Test which defines for tax purposes whether or not an individual is resident in the United Kingdom. The author, Jonathan Schwarz, is a Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems.
Download or read book Residence Domicile and UK Taxation written by Neil D. Booth and published by MICHIE. This book was released on 1986 with total page 255 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Booth Residence Domicile and UK Taxation written by Jonathan Schwarz and published by Bloomsbury Professional. This book was released on 2008-09-01 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This unique work clearly explains the complex concepts of residence, ordinary residence and domicile with extensive reference to the relevant UK and European case law. Now in its 11th edition, it is up-to-date to the Finance Act 2008.
Download or read book Residence and Domicile of Individuals written by and published by . This book was released on 1986 with total page 14 pages. Available in PDF, EPUB and Kindle. Book excerpt: An explanation of the concepts of residence and domicile in UK tax law and their implications for individuals coming to or leaving the UK. Includes appendices summarizing the liability to UK income, capital gains and inheritance taxes of resident, non-resident and non-domiciled individuals.
Download or read book Individual Tax Residence written by Setu Kamal and published by Sweet & Maxwell. This book was released on 2011 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book examines the law relating to individual tax residence. It summarises the rules in statute and common law (including the topical recent high-profile cases). It includes commentary and analysis of this important topic and questions commonly held views as to what steps need to be taken to achieve non-residence
Download or read book Domicile Residence and UK Taxation written by Rano Channan and published by Hamilton U. S. A. Publishers. This book was released on 1993 with total page 142 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Residence in the United Kingdom written by Great Britain. Board of Inland Revenue and published by . This book was released on 1988 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Taxation of non residents and foreign domiciliaries 2016 2017 written by James Kessler and published by . This book was released on 2016 with total page 4416 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of the taxation of foreign domiciliaries, the taxation of non-residents on UK assets and taxation of UK residents on foreign assets. The book states the law as at 1 October 2016. The chapters include the following topics: foreign domicile (tax policy and reforms); public debate on tax avoidance; domicile; residence of individuals; residence of trustees; treaty-residence; year of arrival and departure; exit taxes; temporary non-residence; remittance basis; meaning of remittance; remittance reliefs; mixed funds; income sources and categorization; trading income; entertainers and sportspeople; property income; deduction of interest from property income; interest income; exempt interest of non-residents; dividend income; royalty income; employment income; PAYE; employment income: DT relief; pension and annuity income; discretionary trusts: income tax; IIP trusts; settlor-interested trusts; transfer of assets abroad (transferors, non-transferors, double taxation issues, motive defence); life policies and contracts; offshore funds; offshore income gains; income from offshore funds; accrued income profits; deeply discounted securities; unit trusts; intermediated securities; partnerships; non-residents income tax relief; collection of tax from UK representatives; investment manager exemptions; loans from non-resident companies; rates of tax; personal allowances; national insurance contributions; capital gains of UK residents; gains of non-resident settlor-interested trusts: s.86; capital payments from non-resident trusts: s.87; borrowing by non-resident trusts: Sch 4B; gains of non-resident companies; capital losses; foreign currency issues; exchange control; double taxation agreements; foreign tax credit relief; EU law and UK taxation; deemed domicile for IHT; excluded property for IHT; reservation of benefit; IHT consequences of transfers between trusts; IHT deduction for debts; IHT planning before and after a change of domicile; IHT on death: wills and IOVs; double inheritance taxation; IHT DTAs: India, Pakistan, Italy, France, USA, Switzerland; foreign IHT credit relief; UK domiciliary married to foreign domiciliary; residential property of non-resdients: NRCGT; family home and its chattels; corporate residential property; pre-owned assets; joint accounts; estates of deceased persons (CGT, income tax); who is the settlor; trusts with two or more settlors; situs of assets for IHT; situs of assets for CGT; foreign entities; control connected close and related expressions; permanent establishment and branch/agency; disclosure and compliance; Swiss Tax Agreement (clearance facility, withholding tax); disclosure of information by Swiss authorities; criminal law and professional conduct.
Download or read book Corporate Residence and International Taxation written by Robert Couzin and published by IBFD. This book was released on 2002 with total page 295 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of the case law test for corporate residence, developed mainly in the United Kingdom beginning in the 19th century, the residence definition adopted in the OECD Model Convention and some of its more common variants, and Canadian domestic statutory provisions.
Download or read book Tax Planning for Domiciled and Non Domiciled Individuals 2013 2014 written by Malcolm Finney and published by . This book was released on 2013-10-24 with total page 1260 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book is primarily for practitioners who are involved in providing advice to individuals, trustees and executors concerning the three main taxes, namely income tax, capital gains tax and inheritance tax. Its focus is both the UK domiciled and non-UK domiciled resident individual although the UK tax issues affecting non-residents are also addressed. Numerous examples designed to illustrate the principles and points under discussion appear throughout the text and extensive cross-referencing allows the same topic to be tracked where it is discussed in a different context. Trusts, be they UK resident or offshore, continue to be critical to many aspects of tax planning and their use and abuse form the central core of several chapters in the book. The legal and tax issues underpinning the various types of property ownership are discussed and their application to main residence and furnished holiday lettings examined in detail including the extensive new provisions introduced in Finance Act 2013.For the non-UK domiciled individual whether to claim remittance basis treatment; what constitutes a taxable remittance; and whether the newly introduced business investment relief is tax efficient are all areas of interest and discussed at length. The role of wills in inheritance tax planning (and in general) cannot be overlooked and, in particular, Deeds of Variation and other post-death adjustments are discussed in detail. Many more topics, including international matters and SDLT, are also covered in the book. The text is current as at the date of the Royal Assent of Finance Act 2013.Part I - Basic Issues; Tax systems and their bases of taxation: an overview; UK Taxation: an overview; Domicile; Residence and ordinary residence for the individual; Residence, ordinary residence and domicile: practice; Income source and asset situs; The principles and implications of property ownership: joint tenancy and tenancy in common; Part II - Capital Taxes; Capitan gains tax; Capital losses; Inheritance tax: the basics; Inheritance tax: exemptions and reliefs; Inheritance tax: gifts with reservation; Inheritance tax: excluded property; Inheritance tax administration; Part III - Trusts; Trusts: an overview; Inheritance tax: trusts; UK resident trusts: income and capital gains taxation; Non-UK resident trusts: income and capital gains taxation; Part IV - Investments, main residence and furnished holiday lettings; Investments; Main residence and furnished holiday lettings; Non-UK domiciliaries and UK homes; Stamp duty and stamp duty land tax; Part V - The international dimension; Non-UK resident taxat
Download or read book Schwarz on Tax Treaties written by Jonathan Schwarz and published by Kluwer Law International B.V.. This book was released on 2021-09-28 with total page 870 pages. Available in PDF, EPUB and Kindle. Book excerpt: Schwarz on Tax Treaties is the definitive analysis of tax treaties from United Kingdom and Irish perspectives and provides in-depth expert analysis of the interpretation and interaction of those treaty networks with the European Union and international law. The sixth edition significantly develops the earlier work with enhanced commentary and is updated to include the latest UK, Irish domestic and treaty developments, international and EU law, including: Covered Tax Agreements modified by the BEPS Multilateral Instrument; judicial decisions of Ireland, the UK and foreign courts on UK and Irish treaties; Digital Services Tax; treaty binding compulsory arbitration; Brexit and the EU-UK Trade and Cooperation Agreement; taxpayer rights in exchange of information; taxpayer rights in EU cross-border collection of taxes; attribution of profits to permanent establishments; and EU DAC 6 Disclosure of cross-border planning. Case law developments including: UK Supreme Court in Fowler v HMRC; Indian Supreme Court in Engineering Analysis Centre of Excellence Private Limited and Others v CIT; Australian Full Federal Court in Addy v CoT; French Supreme Administrative Court in Valueclick; English Court of Appeal in Irish Bank Resolution Corporation v HMRC; JJ Management and others v HMRC; United States Tax Court in Adams Challenge v CIR; UK Tax Tribunals in Royal Bank of Canada v HMRC; Lloyd-Webber v HMRC; Esso Exploration and Production v HMRC; Glencore v HMRC; McCabe v HMRC; Padfield v HMRC; Davies v HMRC; Uddin v HMRC; English High Court in Minera Las Bambas v Glencore; Kotton v First Tier Tribunal; and CJEU in N Luxembourg I, and others (the ‘Danish beneficial ownership cases’); État belge v Pantochim; College Pension Plan of British Columbia v Finanzamt München; HB v Istituto Nazionale della Previdenza Sociale. About the Author Jonathan Schwarz BA, LLB (Witwatersrand), LLM (UC Berkeley), FTII is an English Barrister at Temple Tax Chambers in London and is also a South African Advocate and a Canadian and Irish Barrister. His practice focuses on international tax disputes as counsel and as an expert and advises on solving cross-border tax problems. He is a Visiting Professor at the Faculty of Law, King’s College London University. He has been listed as a leading tax Barrister in both the Legal 500, for international corporate tax, and Chambers’ Guide to the Legal Profession, for international transactions and particular expertise in transfer pricing. He has been lauded in Who’s Who Legal, UK Bar for his ‘brilliant’ handling of cross-border tax problems. In Chambers Guide, he is identified as ‘the double tax guru’ with ‘extraordinary depth of knowledge and experience when it comes to tax treaty issues and is a creative thinker and a clear and meticulous writer’.
Download or read book Non resident Offshore Tax Planning 2016 2017 written by Lee Hadnum and published by Createspace Independent Publishing Platform. This book was released on 2016-04-19 with total page 308 pages. Available in PDF, EPUB and Kindle. Book excerpt: New April 2016 Edition fully updated for the latest 2016/2017 changes Leaving the UK and becoming non UK resident offers many tax planning benefits. It isn't just non residence that offers tax planning opportunities. Non UK domiciliaries can also structure their affairs to avoid income tax and capital gains tax as well as inheritance tax. This 325 page tax book is essential reading for: Anyone considering moving abroad to avoid income tax or CGT Anyone planning to work overseas Anyone returning to the UK after a period of non-residence Non UK domiciliaires planning to live in the UK tax efficiently What Information is Contained in the Guide Non-Resident & Offshore Tax Planning is jam-packed full of clear examples and unique tax planning advice. Subjects covered include: Full and comprehensive explanation of terms "Domicile" and "Non Resident". How becoming non-resident could save you a fortune in tax. Fully updated for new residence rules. Latest tax changes from April 2015. The new 15 year (or in practice 13 year) rule for non-doms from April 2017. All about the new Principal Private Residence (PPR) relief rules from April 2015. How to purchase UK property after 2015. How the statutory residence test applies from April 2013. Changes to the tax treatment of UK dividends from April 2016. Detailed analysis of relevant cases on non residence. Exactly how to make a distinct break with UK to avoid UK residence. How to take advantage of loopholes in the Statutory Residence provisions. How HMRC keeps a track on UK visits with new technology. Whether you should or shouldn't be claiming the personal allowance after you leave the UK. How to make capital & income distributions from offshore trusts tax efficiently. Exactly how to establish company residence overseas. Detailed explanations of how to avoid UK tax on your income from rents, dividends, pensions and employment. How you could completely escape capital gains tax both in the UK and abroad. Pitfalls to negotiate when avoiding UK capital gains tax. Tax implications of selling your UK home after you leave the UK. How to lose a UK domicile and how to retain an overseas domicile. How to avoid inheritance tax by losing your UK domicile. How to use your spouse to slash your tax bill. How the changes to the remittance basis will affect non UK domiciliaries AND the opportunities you still have to reduce UK taxes. How the £30,000 and £60,000 annual tax charge for non UK domiciliaries works. How to remit income and capital gains free of UK tax. How the new CGT regime for non-residents from April 2015 will apply What you need to know about the new Business Investment Exemption How foreign nationals can escape UK taxes altogether. Dedicated areas of advice for investors in overseas property. Changes to the treatment of loans for non-doms How Double Tax Relief works and how to make the most of it. How to avoid tax everywhere by becoming a "Tax Nomad". Detailed analysis of the latest changes to the tax treatment of offshore companies A detailed look at when you can and can't use offshore companies and trusts to reduce UK taxes. How overseas investors should invest in UK property. How non UK domiciliaries can use excluded property trusts tax efficiently in 2014/2015 How to save tax with double tax treaties. and much more...
Download or read book No Place Like Home written by S. Saunders and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The author reminds us of the important legislative changes to domicile in April 2017 and considers the various tax implications. Capital gains on UK residential property are taxable in the UK regardless of the individual's residence or domicile status. A UK domiciled individual is taxable on their worldwide income and gains for any year in which they are UK resident.
Download or read book Non Resident and Offshore Tax Planning How to Cut Your Tax to Zero written by L. Hadnum and published by Createspace Independent Publishing Platform. This book was released on 2015-03-17 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: New September 2015 Edition Fully Updated For The 2015 Budget & July 2015 Summer Budget Leaving the UK and becoming non UK resident offers many tax planning benefits. It isn't just non residence that offers tax planning opportunities. Non UK domiciliaries can also structure their affairs to avoid income tax and capital gains tax as well as inheritance tax. This 284 page tax book is essential reading for: Anyone considering moving abroad to avoid income tax or CGT Anyone planning to work overseas Anyone returning to the UK after a period of non-residence Non UK domiciliaires planning to live in the UK tax efficiently What Information is Contained in the Guide Non-Resident & Offshore Tax Planning is jam-packed full of clear examples and unique tax planning advice. Subjects covered include: Full and comprehensive explanation of terms "Domicile" and "Non Resident". How becoming non-resident could save you a fortune in tax. Fully updated for new residence rules. Latest tax changes from April 2015. All about the new Principal Private Residence (PPR) relief rules from April 2015. How to purchase UK property after 2015. How the statutory residence test applies from April 2013. Detailed analysis of relevant cases on non residence. Exactly how to make a distinct break with UK to avoid UK residence. How to take advantage of loopholes in the Statutory Residence provisions. How HMRC keeps a track on UK visits with new technology. Whether you should or shouldn't be claiming the personal allowance after you leave the UK. How to make capital & income distributions from offshore trusts tax effiicently. Exactly how to establish company residence overseas. Detailed explanations of how to avoid UK tax on your income from rents, dividends, pensions and employment. How you could completely escape capital gains tax both in the UK and abroad. Pitfalls to negotiate when avoiding UK capital gains tax. How to protect property investments from the taxman Tax implications of selling your UK home after you leave the UK. The latest non-dom tax changes How to lose a UK domicile and how to retain an overseas domicile. How to avoid inheritance tax by losing your UK domicile. How to use your spouse to slash your tax bill. How the changes to the remittance basis will affect non UK domiciliaries AND the opportunities you still have to reduce UK taxes. How the £30,000 and £60,000 annual tax charge for non UK domiciliaries works. How to remit income and capital gains free of UK tax. How the new CGT regime for non-residents from April 2015 will apply What you need to know about the new Business Investment Exemption How foreign nationals can escape UK taxes altogether. Dedicated areas of advice for investors in overseas property. Changes to the treatment of loans for non-doms How you could claim tax free lump sums whilst working abroad. How Double Tax Relief works and how to make the most of it. How to avoid tax everywhere by becoming a "Tax Nomad". Tax advantages and disadvantages of offshore trusts and companies. Detailed analysis of the latest changes to the tax treatment of offshore companies A detailed look at when you can and can't use offshore companies and trusts to reduce UK taxes. How overseas investors should invest in UK property. How non UK domiciliaries can use excluded property trusts tax efficiently in 2014/2015 How to save tax with double tax treaties. and much more...
Download or read book Non Resident Offshore Tax Planning written by Mr Lee Hadnum and published by Createspace Independent Publishing Platform. This book was released on 2017-09-12 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: New September 2017 Edition fully updated for the latest 2017/2018 changes Leaving the UK and becoming non UK resident offers many tax planning benefits. It isn't just non residence that offers tax planning opportunities. Non UK domiciliaries can also structure their affairs to avoid income tax and capital gains tax as well as inheritance tax. This 325 page tax book is essential reading for: Anyone considering moving abroad to avoid income tax or CGT Anyone planning to work overseas Anyone returning to the UK after a period of non-residence Non UK domiciliaires planning to live in the UK tax efficiently What Information is Contained in the Guide? Non-Resident & Offshore Tax Planning is jam-packed full of clear examples and unique tax planning advice. Subjects covered include: Full and comprehensive explanation of terms "Domicile" and "Non Resident". How becoming non-resident could save you a fortune in tax. Fully updated for new residence rules. Latest tax changes from April 2017. The new 15 year (or in practice 13 year) rule for non-doms from April 2017. All about the new Principal Private Residence (PPR) relief rules from April 2015. How to purchase UK property tax efficiently. How the statutory residence test applies. Changes to the tax treatment of UK dividends from April 2016. Detailed analysis of relevant cases on non residence. Exactly how to make a distinct break with UK to avoid UK residence. How to take advantage of loopholes in the Statutory Residence provisions. How HMRC keeps a track on UK visits with new technology. Whether you should or shouldn't be claiming the personal allowance after you leave the UK. How to make capital & income distributions from offshore trusts tax efficiently. Exactly how to establish company residence overseas. Detailed explanations of how to avoid UK tax on your income from rents, dividends, pensions and employment. How you could completely escape capital gains tax both in the UK and abroad. Pitfalls to negotiate when avoiding UK capital gains tax. Tax implications of selling your UK home after you leave the UK. How to lose a UK domicile and how to retain an overseas domicile. How to avoid inheritance tax by losing your UK domicile. How to use your spouse to slash your tax bill. How the changes to the remittance basis will affect non UK domiciliaries AND the opportunities you still have to reduce UK taxes. How the �30,000 and �60,000 amd �90,000 annual tax charge for non UK domiciliaries works. How to remit income and capital gains free of UK tax. How the new CGT regime for non-residents applies from April 2015 applies What you need to know about the new Business Investment Exemption How foreign nationals can escape UK taxes altogether. Dedicated areas of advice for investors in overseas property. Changes to the treatment of loans for non-doms. How Double Tax Relief works and how to make the most of it. How to avoid tax everywhere by becoming a "Tax Nomad". Detailed analysis of the latest changes to the tax treatment of offshore companies A detailed look at when you can and can't use offshore companies and trusts to reduce UK taxes. How overseas investors should invest in UK property. How non UK domiciliaries can use excluded property trusts tax efficiently in 2017/2018 How to save tax with double tax treaties.
Download or read book Tax Planning The Statutory Residence Test written by L Hadnum and published by . This book was released on 2021-06-23 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Statutory Residence Test ("SRT") applies from April 2013 and aims to provide a comprehensive method of clearly establishing when an individual will (and won't) be UK resident. Before April 2013 determining your residence status mainly depended on applying HMRC practice and various court decisions to your own circumstances. Nevertheless, the Statutory Residence rules are not necessarily straightforward to apply. In this guide we provide detailed guidance as to how the new rules apply and the tax planning opportunities available. Some of the key topics covered include: How to maximise your days in the UK without being UK resident How to take advantage of the specific exemptions provided in the SRT Detailed analysis of UK accommodation and its importance under the SRT When you can and can't have a UK home Avoiding UK ties under the "Substantial Ties" test Tax planning for anyone working overseas or in the UK under the SRT The impact of overseas homes under the SRT How to establish your main home as overseas How to structure visits back to the UK tax efficiently How the new "exceptional days" provisions work Changes arising from the COVID-19 pandemic When you can qualify for the split year basis How the split year basis applies to fiscal nomads How to avoid being caught by the new "deemed days" provisions Fiscal nomads and the establishing non residence under the SRT When and how to use the SRT in earlier years Why your spouse's residence can have a big impact on your tax residence Using a UK double tax treaty to work in the UK free of UK income tax And much more...
