Taxation of non-residents and foreign domiciliaries : 2016-2017

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.