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Taxation of Non-Residents and Foreign Domiciliaries 2023-2024 22nd ed

James Kessler

ISBN13: 9781901614916

New Edition ISBN: 9781901614930

Previous Edition ISBN: 9781901614886

Published: June 2023

Publisher: Key Haven Publications PLC

Country of Publication: UK

Format: Paperback, 9 Volumes

Price: Out of print

Contents include the most thorough analysis ever published of:

Taxation of foreign domiciliaries
Taxation of non-residents on UK income and assets
Taxation of UK residents on foreign income and assets

Subjects:: Taxation

Contents:: Volume 1; Introduction and What’s New; Obtaining further advice and disclaimer; Non-dom policy & avoidance; 1. Foreign Domicile: Tax Policy; 2. Tax Avoidance; 3. TAARs; Domicile & residence; 4. Domicile; 5. Deemed Domicile; 6. Residence of Individuals; 7. Residence of Trustees; 8. Residence of Companies; 9. Treaty-Residence; 10. Split Years: Arrival and Departure; 11. Temporary Non-residence; Volume 2; 12. Exit Taxes; 13. UK Arrival or Departure: Tax Checklist; Income tax: Principles & remittance basis; 14. Income Categorisation; 15. Income Recognition: Received /Entitled/Arise/Paid; 16. Source/RFI/Territorial Principles; 17. The Remittance Basis; 18. The Meaning of Remittance; 19. Remittance Reliefs; 20. Mixed Funds; Income by category; 21. Trading Income; 22. Trading in Land; 23. Performers; 24. Property Income; 25. Deduction of Interest from Property Income; 26. Interest Income; Volume 3; 27. Exempt Interest of Non-Residents; 28. Accrued Income Profits; 29. Deeply Discounted Securities; 30. Dividend Income; 31. Annual Payments; 32. Intellectual Property Income; 33. Misc Sweep-Up Income; 34. Employment Income; 35. Travel Expenses: Employment Income; 36. PAYE; 37. Employment Income: DT Relief; 38. Pension and Annuity Income; 39. Benefit in Kind: Family Home and Chattels; 40. Benefit in Kind: Loans from Non-Resident Companies; IT: general; 41. Discretionary Trusts: Income Tax; 42. IIP Trusts: Income Tax; 43. Rates of Income Tax: CGT; 44. Personal Allowances; 45. Non-Resident Income Tax Relief; 46. National Insurance Contributions; Volume 4; IT avoidance codes; 47. Settlor-Interested Trust Code; 48. Transfer of Assets Abroad: Introduction; 49. Transfer of Assets Abroad: Transferors; 50. Transfer of Assets Abroad: Benefits; 51. Transfer of Assets Abroad: Relief From Overlapping Charges; 52. Transfer of Assets Abroad: Motive Defence; 53. Profit Fragmentation; 54. Transfer of Income Stream; 55. Transactions in Securities; Capital Gains Tax; 56. Chargeable Gains; 57. UK Property held by Non-residents; 58. Residential Property: CGT; 59. Gains of Non-resident Settlor-interested Trust: s.86; Volume 5; 60. Capital Payments from Non-resident Trusts: s.87; 61. Borrowing by Non-resident Trusts: Sch 4B; 62. Sub-funds; 63. Gains of Non-resident Companies; 64. Capital Losses; Funds; 65. Life Policies and Contracts; 66. Offshore Income Gains; 67. Income from Offshore Funds; 68. Unit Trusts; 69. Intermediated Securities; 70. Investment Manager Exemptions; 71. Investment Management Fees & Carried Interest; Inheritance Tax; 72. IHT Terms and Concepts; 73. Excluded Property: Definition; 74. Excluded Property Exemptions; 75. Wills and IOVs; 76. Reservation of Benefit; 77. Inter-trust Transfers: IHT; Volume 6; 78. IHT Deduction for Debts; 79. IHT Close-company Code; 80. IHT Residential Property Code; 81. Pe-owned Assets; 82. Pension Schemes and IHT; Entities; 83. Partnerships; 84. Partnership Income Attribution; 85. Settlement, Bare Trust and Associated Terminology; 86. Estates of Deceased Persons: CGT; 87. Estates of Deceased Persons: Income Tax; 88. Foreign Entities; 89. Hybrid Entities; Concepts & topics affecting more than one tax; 90. Protected Trusts; 91. Non-dom/Non-resident Spouse; 92. Joint Accounts; Volume 7; 93. Foreign Currency Issues; 94. Unremittable Assets; 95. ATED and SDLT; 96. Who is the Settlor; 97. Multiple Settlors; 98. Statutory Tax Indemnities; 99. Situs of Assets for IHT; 100.Situs of Assets for CGT; 101.Control, Connected, Close and Related Expressions; 102.Participation and % Interest Tests; 103.Permanent Establishment and Branch/Agency; 104.Post-Brexit EU Law; Double Taxation Agreements: IT/CGT; 105.Double Taxation Arrangements: Introduction; 106.DTA Anti-Abuse Rules; 107.Limitation on Benefits; 108.Credit for Foreign Tax; 109.Non-discrimination; Double Taxation Agreements: IHT; 110.IHT Double Taxation Treaties: Introduction; Volume 8; 111.IHT DTAs: India, Pakistan, Italy, France; 112.IHT DTA: Netherlands; 113.IHT DTA: South Africa; 114.IHT DTA: Switzerland; 115.IHT DTA: USA; 116.Credit for Foreign IHT Administration; 117.Reporting and Compliance; 118.Tax Return Filing Position; 119.Claims; 120.Collection of Tax from UK Representatives; 121.Reporting and Compliance: IHT; 122.Penalties; 123.Failure to Prevent Tax Evasion; 124.Common Reporting Standard; 125.Trust Registration; 126.Reporting Offshore Trusts; 127.International Movement of Capital: Reports; 128.Money Laundering; Appendices; Words & Concepts; Appendix 1: Words of Dispute; Appendix 2: Common Legal Expressions; Appendix 3: Family Terminology; Appendix 4: Consideration, Arm’s Length, Full Value; Appendix 5: Commercial/View to Profit; Appendix 6: Beneficial Ownership/Entitlement; Appendix 7: Offshore Funds/CIS/OEIC Appendix 8: What Do We Mean by “Real”?; Construction of Statutes; Appendix 9: Deeming Provisions; Appendix 10: Purpose of Statute; Special Taxpayers; Appendix 11: Parliamentarians Appendix 12: Visiting Forces Appendix 13: Students and Teachers; Tax reform; Appendix 14: How to Improve Residence and Domicile Taxation; Appendix 15: Reform of Offshore Anti-avoidance Law; Appendix 16: The Wisdom of Parliament; Index