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

James Kessler KC

ISBN13: 9781901614930

New Edition ISBN: 9781068367519

Previous Edition ISBN: 9781901614916

Published: June 2024

Publisher: Key Haven Publications PLC

Country of Publication: UK

Format: Paperback, 9 Volumes

Price: Out of print

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

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