Taxation of Non-Residents and Foreign Domiciliaries 2024-2025 23rd Edition

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Taxation of Non-Residents and Foreign Domiciliaries 2024-2025 23rd Edition

By James Kessler KC
Key Haven Publications PLC June 2024

Specifications

ISBN-13
9781901614930
Publisher
Key Haven Publications PLC
Publication
June 2024
Format
Paperback (9 volumes)
Jurisdiction
U.K. ? Countri(es) for reference only
Price on request
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Details

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

Published in 9 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

Table of 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
Price on request
New Edition is available now !
  • Free HK shipping over HK$1,000
  • International shipping to 35+ countries
Order Form
Save

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