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Tolley's Tax Planning for Owner-Managed Businesses 2017-18

Tolley's Tax Planning for Owner-Managed Businesses 2017-18

Author: Paula Tallon; Paul Howard, Gabelle LLP
Publisher: LexisNexis U.K.
ISBN: 9780754553960

Previous Edition ISBN: 9780754552734
Published In: December 2017
Format: Paperback
Jurisdiction: U.K. ? Disclaimer:
Countri(es) stated herein are used as reference only

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In the current climate, businesses are expecting their advisers to help them make more savings through careful tax planning than ever before. This title enables you to give real-life solutions and guidance on problems faced in every stage of the life-cycle of an owner-managed business.

All the key issues are covered in a clear and precise manner, including the interaction of different taxes and the Finance Act 2017, to ensure there is a thorough analysis of planning opportunities in each transaction or event.

Written by providers of advice to practitioners and their clients, this practical title uses worked examples and case studies to explain tax liabilities, compliance and planning opportunities available for tax mitigation, and, as such, is essential reading for anyone handling the affairs of owner-managed businesses.

Preface

Author Biographies

Table of statutes

Table of statutory instruments

Table of cases

PART A PLANNING

Section I: UK Resident and Domiciled Individuals: use of

Offshore Structures as Tax Shelters

1 Offshore trusts

2 Offshore companies

3 Offshore funds

4 Life policies

5 Overview

6 Holding companies

7 Traps and pitfalls

8 Income distributions

9 Capital distributions

10 Planning points in relation to capital distributions

11 Bringing the trust onshore

12 Basic planning

13 Pre-arrival planning

14 Bringing money to the UK

15 Identifying non-UK investments

16 Mitigating tax on UK investments

17 Home ownership

18 Creating offshore settlements

19 Foundations

20 Anticipating UK domicile or deemed domicile

21 General

22 Provision for the settlor

23 Provision for other beneficiaries

24 CGT planning

25 Sheltering business profits

26 Employee benefit trusts

27 Investment in real estate by offshore companies

28 UK houses for non-residents

29 Emigration

30 Migration of trusts

31 Company migration

PART B THE DOMESTIC LEGAL FRAMEWORK

32 Characterisation

33 Characterisation of foundations

34 Sham trusts

35 Territorial limits

36 Situs of assets: general rules

37 CGT situs rules

38 Source

39 The residence of individuals

40 Residence of trusts

41 Residence of companies

42 Domicile: general principles

43 Domicile for inheritance tax

44 Eligibility for the remittance basis

45 Long-term residents: the annual charge for the remittance basis

46 Relevant foreign income

47 Foreign chargeable gains

48 Earnings

49 Core meaning of ‘remittance’

50 Derivation

51 Mixed funds

52 Relevant persons

53 Services provided in the UK

54 Debts relating to property enjoyed in the UK

55 Anti-avoidance provisions: Conditions C and D

56 Business investment relief

57 Other exemptions from tax on remittances

58 The relevant property regime

59 Exceptions to the relevant property regime

60 Excluded property and settlements

61 Excluded property and the relevant property regime

62 UK income of non-residents

63 UK gains of non-residents

64 ATED and ATED related CGT

65 Stamp duty land tax

66 Relevant transfers

67 Transferors

68 Non-transferors

69 The s 733 computation

70 Non-UK domiciliaries

71 The motive defence

72 European defence

73 Attribution of income to the settlor

74 Attribution of gains to the settlor

75 Section 87

76 Capital payments

77 Capital payments and non-UK domiciliaries

78 Trustee borrowing

79 Schedule 4C pools

80 Trust offshore income gains

81 Reservation of benefit rules

82 The IHT treatment of liabilities due from individuals

83 The IHT treatment of liabilities: trusts and reservations of benefit

84 Pre-owned assets

85 The general anti-abuse rule

86 Close companies

87 Corporate gains: section 13

88 Transfer pricing

89 Diverted profits tax

90 Benefits in kind

91 Employment income provided through third parties

92 Offshore funds

93 The regime applicable to life policies

94 Introduction to DTTs

95 Treaty residence

96 Overview of distributive articles

97 Availability of relief

98 Problem entities

99 DTTs and anti-avoidance legislation

100 The fundamental freedoms

101 Impact of the freedoms on anti-avoidance legislation

102 The Liechtenstein Disclosure Facility

103 The UK/Swiss Tax Cooperation Agreement

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New Edition is available now !

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