Non-doms


Domicile dramas

26 July 2018

Many advisers have to grapple with the sometimes difficult question of establishing their client’s domicile. A client’s domicile is fundamentally important in a diverse range of English legal and tax areas, such as whether: a client can bring divorce proceedings in the UK; a client is liable to UK Inheritance Tax on worldwide assets as […]

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Capital Gains Tax and offshore trusts: match fit for April 2018?

14 December 2017

The UK’s Autumn Budget contained a welcome lack of new measures affecting the capital gains taxation of offshore (i.e. non-UK) trusts.  However, there are Capital Gains Tax changes waiting in the wings, already announced, coming into effect on 6 April 2018.  There may be steps that UK resident non-doms and their trustees ought to be […]

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Long term UK resident non-doms set to lose remittance basis of taxation

6 October 2016

Anyone who does not regard England as their permanent home (non-dom) but who has been resident in the UK for at least 15 out of the past 20 income tax years will wake up to a very different UK tax regime on 6 April 2017, according to a further consultation issued by the Government on […]

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UK residential properties held through offshore structures: a call to action

8 September 2016

Owners of UK residential property held through offshore structures, including non-UK companies and partnerships, should urgently review their structures following the publication of a further consultation by the UK Government on 19 August 2016. The consultation confirms that residential properties in these structures will be exposed to UK Inheritance Tax (IHT) from 6 April 2017. […]

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Brexit exits – don’t get caught out by the IHT deemed domiciled rules

30 June 2016

Brexit uncertainties may be giving fresh impetus to many UK resident non-UK domiciliaries who are thinking about their residency plans. However, for res non-doms, it’s important not to lose sight of another key tax change now on the horizon – the change in the Inheritance Tax (IHT) deemed domiciled rules. A person is deemed domiciled […]

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Changes to business investment relief: a sop to non-doms?

10 December 2015

Business investment relief (BIR) has been a feature of the UK tax system since April 2012 and it is unusual, being the only exception to the remittance basis of taxation that is ‘purpose-specific’. BIR allows UK resident non-doms to bring into the UK untaxed foreign income and foreign gains without making a taxable remittance of […]

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