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Guide to US/UK Private Wealth Tax Planning 2nd ed

Robert L Williams, Withers LLP

ISBN13: 9781847665096
Previous Edition ISBN: 1845920279
Published: June 2016
Publisher: Bloomsbury Professional
Country of Publication: UK
Format: Paperback
Price: Out of print





This unique book is a concise but complete tax planning manual for high net worth individuals of the UK, US or any other nationality who have UK or US residence, assets or family members.

It covers all the information and legislation you are likely to require when advising clients exposed to both UK and US taxation, providing you with:-

  • a quick reference summary of the UK and US rules applicable to your clients;
  • a comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US;
  • optimal income and gains tax planning for foreign trusts with UK or US beneficiaries;
  • and integrated UK and US tax planning solutions for clients exposed to both UK and US tax.

Subjects:
Taxation
Contents:
  • Part I: Outline of Relevant Taxes
    • Section 1: Principal taxes
    Chapter 1 Taxation status in the US: overview
    Chapter 2 US: transfer tax system
    Chapter 3 US: transfer taxes: marital deduction
    Chapter 4 US: state death and inheritance taxes
    Chapter 5 US: tax on capital gains
    Chapter 6 US: tax basis rules for gifts and bequests
    Chapter 7 US: income tax
    Chapter 8 Overview of principal UK taxes
    Chapter 9 UK: inheritance tax on individuals
    Chapter 10 UK: pre-owned asset tax
    Chapter 11 UK: income tax
    Chapter 12 UK: capital gains tax
    Chapter 13 UK: the arising basis and the remittance basis
    Chapter 14 UK: corporation tax
    Chapter 15 UK: annual tax on enveloped dwellings
    Chapter 16 UK: stamp duty land tax
    Section 2: Tax status and basis of taxation
    Chapter 17 US: citizenship
    Chapter 18 US expatriation
    Chapter 19 US: income tax residence rules for foreign nationals
    Chapter 20 US: trust residence (income tax)
    Chapter 21 US: income taxation of non-resident aliens and foreign corporations
    Chapter 22 US: domicile and transfer taxation of non domiciliaries
    Chapter 23 US: situs of assets taxable to non domiciliaries
    Chapter 24 Taxation status in the UK: overview
    Chapter 25 UK nationality
    Chapter 26 UK: domicile
    Chapter 27 UK: residence of individuals
    Chapter 28 UK: residence of trustees
    Chapter 29 UK: residence of companies
    Chapter 30 UK: situs
    Section 3: Trust and estate taxation
    Chapter 31 US: transfer taxes on trusts
    Chapter 32 US: grantor trusts
    Chapter 33 US: non-grantor trusts
    Chapter 34 US: special needs trusts
    Chapter 35 US: intentionally defective grantor trusts
    Chapter 36 Crummey Powers
    Chapter 37 US: qualified personal residence trust
    Chapter 38 US: taxation of deceased's estates and beneficiaries
    Chapter 39 GRATs
    Chapter 40 UK: inheritance tax on trustees
    Chapter 41 UK: trusts – income tax and capital gains tax
    Chapter 42 UK taxation of personal representatives
    Section 4: Taxation on corporations
    Chapter 43 US and Treaty entity classification rules – corporations, partnerships and branches
    Chapter 44 US: private trust companies
    Chapter 45 US: passive foreign investment companies
    Chapter 46 US: controlled foreign corporations
    Chapter 47 US: partnership interests of non-US persons
    Chapter 48 US: non-US corporations and estate tax
    Chapter 49 US: treatment of non-US entities
    Chapter 50 UK: UK tax classification of non-UK entities
    Chapter 51 UK: companies
    Chapter 52 UK controlled foreign companies
    Chapter 53 UK: partnerships
    Chapter 54 UK: offshore funds and offshore income gains
    Section 5: Charities
    Chapter 55 US charities
    Chapter 56 UK: taxation of gifts to charity
    Section 6: Insurance
    Chapter 57 US: life insurance policies
    Chapter 58 UK: qualifying and non-qualifying insurance policies
    Chapter 59 UK: personal portfolio bonds
    Section 7: Compliance
    Chapter 60 US compliance: 12 foreign tax reporting forms
    Chapter 61 US: withholding tax regulations
    Chapter 62 US FATCA
    Chapter 63 US requirement for reporting of foreign financial accounts FBAR and tax FBAR annual reports
    Chapter 64 US offshore voluntary disclosure program
    Chapter 65 US foreign trusts' reporting requirements
    Chapter 66 UK: self assessment
    Chapter 67 UK: trust reporting
    Chapter 68 UK: tax information exchange measures
    Chapter 69 UK: general anti-avoidance legislation
    Section 8: US-UK Treaties
    Chapter 70 The US-UK Income Tax Treaty
    Chapter 71 The US/UK estate and gift tax treaty

    Part II: Planning
    Chapter 72 UK: pre-immigration planning
    Chapter 73 US: pre-immigration planning
    Chapter 74 Expatriation
    Chapter 75 Lifetime giving
    Chapter 76A Spouses and civil partners: lifetime planning
    Chapter 76B Spouses and civil partners: testamentary planning
    Chapter 76C Spouses and civil partners: jointly-owned property
    Chapter 76D Divorce planning
    Chapter 77 Insurance planning
    Chapter 78 Trusts and partnership planning: forming trusts and other entities
    Chapter 79 Trusts and partnership planning: planning with existing trusts
    Chapter 80 Wills
    Chapter 81 Probate and the administration of estates: tax issues for personal representatives
    Chapter 82 Post-death variations and disclaimers
    Chapter 83 Giving to charity

    Appendix I: US Tax Tables 2016/2017
    Appendix II: UK Tax Tables 2016/17
    Appendix III: 2001 United Kingdom-United States Income Tax Treaty (conformed to include the 2002 Protocol)
    Appendix IV: 1978 United Kingdom-United States Estate and Gift Tax Treaty
    Appendix V: The American Diaspora, Innocents Abroad
    Appendix VI: FATCA, IGAs, and the OECD CRS: The Future Landscape for Trusts
    Appendix VII: Trust and Company Strategies to Avoid Penal US Tax Exposures.