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Taxation of Non-Residents and Foreign Domiciliaries 2024-2025 23rd ed: ONLINE ACCESS

James Kessler

ISBN13: 9781901614923

Previous Edition ISBN: 9781901614909

Published: May 2024

Publisher: Key Haven Publications PLC

Country of Publication: UK

Format: Online Access

Price: £515.00

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Taxation of Non-Residents and Foreign Domiciliaries is the bible of those giving tax advice to foreign clients living in the UK.

Published in 8 volumes, the annual edition provides comprehensive information about:

Taxation of foreign domiciliaries
Taxation of non-residents on UK income and assets
Taxation of UK residents on foreign income and assets
Other topics arising in this context, including tax avoidence and disclosure and compliance

Please note the price shown is for online access for one named user. If multi-user access is required please e-mail enquiries@wildy.com for pricing.

Subjects:: Taxation

Contents:: 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; 11 Temporary Non-residence; 12 Exit Taxes; 13 UK Arrival or Departure: Tax Checklist; Income tax: Principles & remittance basis; 14 Income and its Categorisation; 15 Source/RFI/Territorial Principles; 16 Income Recognition: Receive/Entitled/Arise/Paid; 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; 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/CT; 44 Personal Allowances; 45 Non-Residents Income Tax Relief; 46 National Insurance Contributions; 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 Streams; 55 Transactions in Securities; Capital Gains Tax; 56 Chargeable Gains; 57 UK Property held by Non-residents; 58 Reorganisations; 59 Residential Property: CGT; 60 Gains of Non-Resident Settlor-Interested Trusts: s.86; 61 Capital Payments from Non-Resident Trusts: s.87 code; 62 Borrowing by Non-resident Trusts: Sch 4B; 63 Sub-Funds; 64 Gains of Non-Resident Companies; 65 Capital Losses; Funds; 66 Funds: Terms & concepts; 67 Offshore Income Gains; 68 Income from Offshore Funds; 69 Unit Trusts; 70 Life Policies and Contracts; 71 Intermediated Securities; 72 Investment Manager Exemptions; 73 Investment Management Fees & Carried Interest; Inheritance Tax; 74 IHT Terms and Concepts; 75 Excluded Property: Definition; 76 Excluded Property Exemptions; 77 Wills and IOVs; 78 Reservation of Benefit; 79 Inter-Trust Transfers: IHT; 80 IHT Deduction for Debts; 81 IHT Close-company Code; 82 IHT Residential Property Code; 83 Pre-Owned Assets; 84 Pension Schemes and IHT; Entities; 85 Partnerships; 86 Partnership income: Attribution; 87 Settlement, Bare Trust, and Associated Terminology; 88 Estates of Deceased Persons: CGT; 89 Estates of Deceased Persons: Income Tax; 90 Foreign Entities; 91 Hybrid Entities; Topics affecting more than one tax; 92 Protected Trusts; 93 Non-Dom/Non-Resident Spouse; 94 Joint Accounts; 95 Foreign Currency Issues; 96 Cryptoassets; 97 Unremittable Assets; 98 ATED and SDLT; 99 Who is the Settlor?; 100 Multiple Settlors; 101 Statutory Tax Indemnities; 102 Situs of Assets for IHT; 103 Situs of Assets for CGT; 104 Control, Connected, Close and Related Expressions; 105 Participation & % interest tests; 106 Permanent Establishment and Branch/Agency; Double Taxation Agreements: IT/CGT; 107 Double Taxation Arrangements: Introduction; 108 DTA Anti-Abuse Rules; 109 Third Party Relief/Savings Clause; 110 Limitation on Benefits; 111 Credit for Foreign Tax; 112 Non-discrimination; 113 Mutual agreement proceedure; Double Taxation Agreements: IHT; 114 IHT Double Taxation Treaties: Introduction; 115 IHT DTAs: India, Pakistan, Italy, France; 116 IHT DTA: Netherlands; 117 IHT DTA: South Africa; 118 IHT DTA: Switzerland; 119 IHT DTA: USA; 120 Credit for Foreign IHT; Administration; 121 Reporting and Compliance; 122 Tax Return Filing Position; 123 Claims; 124 Collection of IT/CGT from UK Representatives; 125 Reporting and Compliance: IHT; 126 Penalties; 127 Failure to Prevent Tax Evasion; 128 Reporting Offshore Trusts; 129 International Movement of Capital: Reports; CRS & Money Laundering; 130 Common Reporting Standard; 131 Trust Registration (TRS); 132 Customer Due Diligence; 133 Money Laundering: POCA; Appendices:; Words & Concepts; 1 Words of Dispute; 2 Common Legal Expressions; 3 Family Terminology; 4 Consideration/Arm's Length/Full Value; 5 Commercial/View to Profit; 6 Beneficial Ownership/Entitlement; 7 What do we mean by “Real”?; Statutory construction; 8 Deeming Provisions; 9 Purpose of Statute; Special taxpayers; 10 Parliamentarians; 11 Visiting Forces; 12 Students and Teachers; Tax reform; 13 How to Improve Residence and Domicile Taxation; 14 Reform of Offshore Anti-Avoidance Law; 15 Citizenship-based Taxation; 16 The Wisdom of Parliament