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    latest tax articles

    Tax planning for partners and the new 50% rate of income tax
    19/03/2010
    Tax planning for partners and the new 50% rate of income tax As members will no doubt be aware as from April 2010 the top rate of income tax for anyone earning over £150,000 will be 50%. Partners in particular will be keen to reduce the tax burden as they will be taxed personally on the business profits. The new 50% tax rate will therefore hit them particularly hard. In this article we look at some of the main ways that Partnerships could look to reduce income tax. . . . keep reading
    How setting up a revocable life interest trust can reduce income tax
    17/03/2010
    How setting up a revocable life interest trust can reduce income tax As from 6 April there will be a new 'Super' rate of income tax set at 50%. What's not often appreciated though is that this will then represent the main rate of tax for discretionary trusts. In this article we look at how the new tax rate for trusts will apply and how trustees can use a revocable life interest trust to reduce the income tax charge . . . keep reading
    Reducing tax on property development by using a trust
    15/03/2010
    Reducing tax on property development by using a trust One possibility to reduce tax on property development is by using a trust. The general idea would be that you could save the 40% or 50% income tax charge you'd be subject to if you did the development in your own name by using a trust. The trust could be subject to income tax at the basic rate of 20%. There could therefore be a significant tax saving. . . . keep reading
    Some thoughts on a possible Statutory Residence Test
    12/03/2010
    Some thoughts on a possible Statutory Residence Test Given the UK residency rules are, to say the least, currently pretty vague there's speculation that the Government will introduce a Statutory Residency Test. In this article we look at how such a test could be formulated and what impact this would have on prospective emigrants . . . keep reading
    Ordinary residence in 2010 following the Tucza decision
    10/03/2010
    Ordinary residence in 2010 following the Tucza decision Following a request from a member we've looked at the potentially important case of Andreas Tucza, which addresses UK ordinary residence status. Just like the Gaines Cooper and Grace decisions looked at residence status under common law, the Tucza case looks at ordinary residence status following a review of the case law. . . . keep reading
    Are companies now at risk of making unlawful dividends?
    08/03/2010
    Are companies now at risk of making unlawful dividends? Following a request from a member this article looks at whether companies and their shareholders are at risk of making unlawful dividends. In particular where they are not making the same level of profits as in previous years and yet continue to extract regular dividends it's been suggested HMRC could challenge the validity of the dividends for tax purposes . . . keep reading
    Saving SDLT on property purchases
    05/03/2010
    Saving SDLT on property purchases In this article we look at some of the SDLT planning opportunities for property developers. Although the property market is in a slump development will eventually pick up again, and especially in today's economic climate reducing costs is as important as ever. . . . keep reading
    How to ensure your termination payment isn't taxed as earnings
    03/03/2010
    How to ensure your termination payment isn't taxed as earnings In this article we look at when under general law termination receipts can be taxed as earnings and the impact of this. In addition we look at practical issues that could be considered to ensure the receipts are taxed under the special termination provisions . . . keep reading
    Advanced tax planning for non doms using offshore trusts to purchase UK property
    1/03/2010
    Advanced tax planning for non doms using offshore trusts to purchase UK property Here's one option for some advanced tax planning for non doms looking to remit offshore income gains into the UK free of UK tax. It looks at a strategy to purchase property in your own name using offshore funds whilst avoiding UK CGT and IHT . . . keep reading
    Detailed example of how the nominated income rules apply for non doms
    26/02/2010
    Detailed example of how the nominated income rules apply for non doms The nominated income rules which apply to non doms are particularly complex. In this article we look at a more detailed example to illustrate how they will apply, and in particular how future remittances of overseas income or gains would be taxed in the UK. . . . keep reading
    What the 2010 Gaines Cooper judgement means for anyone looking to establish non residence.
    24/02/2010
    What the 2010 Gaines Cooper judgement means for anyone looking to establish non residence. Since the judgement on 16 February there's been a lot of press coverage of its impact- but what has actually changed? In this article we look at the impact of the Court of Appeal decision and what it means for current or prospective non UK residents . . . keep reading
    QC's view on how to establish a company as non resident
    22/02/2010
    QC's view on how to establish a company as non resident Essential reading for anyone interested in using an offshore company to reduce UK tax. In this article we look at the views of one of the top tax QC's on how to establish an offshore company as non UK resident . . . keep reading
    Offshore Foundations and the remittance basis for CGT purposes
    19/02/2010
    Offshore Foundations and the remittance basis for CGT purposes Offshore foundations are of interest to many of our members, particularly non doms who can benefit from the remittance basis of tax. In this article we look at exactly how offshore foundations and their UK members/founders are taxed on capital gains . . . keep reading
    Inheritance tax and your family company
    17/02/2010
    Inheritance tax and your family company Given the current rate of inheritance tax is 40% this can represent a substantial tax charge, particularly if you have valuable assets such as shares in your family company. In this article we look at when and how such shares can and can't qualify for inheritance tax relief . . . keep reading
    Using estate tax treaties to avoid the deemed domicile rules
    15/02/2010
    Using estate tax treaties to avoid the deemed domicile rules Irrespective of your actual 'domicile' you can be treated as a deemed UK domiciliary which will result in your worldwide estate being subject to UK inheritance tax. In this article we look at how estate tax treaties can be used to prevent you being classed as a deemed domiciliary and how this can avoid UK inheritance tax. . . . keep reading
    Using Pre and Post Nuptial Agreements To Avoid The "50% Divorce Tax"
    Using Pre and Post Nuptial Agreements To Avoid The "50% Divorce Tax" Pre and Post nuptial agreements are increasingly of use to anyone looking to avoid the so called '50% Divorce Tax'.This article reviews the position following recent cases to assess how effective they are in 2010. . . . keep reading
    Should you make the foreign capital loss election - weighing up the pro's and con's
    10/02/2010
    Should you make the foreign capital loss election - weighing up the pro's and con's This is a once and for all election and therefore it's very important to get it right. Following a forum post we've recapped on the pro's and con's of non doms making the foreign capital loss election. . . . keep reading
    Qualifying Recognised Overseas Pension Schemes (QROPS) and investments in UK property
    08/02/2010
    Qualifying Recognised Overseas Pension Schemes (QROPS) and investments in UK property Following an HMRC amendment in October 2009, this article looks at the UK tax implications of a QROPS investing in UK residential property and why you need be careful as to the location of your QROPS investments. . . . keep reading
    New non dom guidance on transfers of forex between overseas foreign currency accounts
    05/02/2010
    New non dom guidance on transfers of forex between overseas foreign currency accounts There's been a lot of changes in the HMRC guidance relating to forex for non doms over the last 6 months or so. In this article we look at the impact of the latest guidance on capital gains and transfers between overseas foreign currency accounts . . . keep reading
    Migrating a UK company and the impact of double tax treaties
    03/02/2010
    Migrating a UK company and the impact of double tax treaties We looked in a previous article at the two main methods of how a UK company can 'migrate' from the UK. In this article we'll look in more detail at a migration by transferring the management & control of a company overseas. . . . keep reading
    Should you set up a new company for trading overseas?
    01/02/2010
    Should you set up a new company for trading overseas? If you are considering trading overseas, you may be considering whether to trade via a branch of an existing UK company or alternatively form a separate (usually overseas) company to carry out the trade. This article looks at the pro's and con's of setting up a new company to carry out the overseas trade. . . . keep reading
    Transferring your UK company overseas to avoid UK tax
    Transferring your UK company overseas to avoid UK tax Some of the UK's largest companies have transferred their operations overseas. In this article we look at how a UK company can 'migrate' overseas tax efficiently and the tax benefits in doing so. . . . keep reading
    New rules to prevent capital losses on forex for non doms
    27/01/2010
    New rules to prevent capital losses on forex for non doms HMRC have announced details of the new provisions to be introduced to prevent capital losses being crystallised on foreign currency conversions in certain limited circumstances. In this article we look at the nature and impact of the changes . . . keep reading
    Establishing an overseas domicile of choice in 2010
    25/01/2010
    Establishing an overseas domicile of choice in 2010 Losing a UK domicile and establishing a domicile of choice overseas can be very advantageous in terms of reducing UK inheritance tax as well as in terms of UK succession law. This article looks as how to establish an overseas domicile of choice in 2010. . . . keep reading
    Tax deduction for travelling expenses if working abroad
    22/01/2010
    Tax deduction for travelling expenses if working abroad Following a request from a site member we've looked at the tax rules relating to obtaining tax relief for travel expenses for you and your close family if you work abroad. This article looks at exactly when you will qualify for a tax deduction for your travelling costs . . . keep reading
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    Recent Forum Posts - New Forums
    • Gaines Cooper Implications - 2
    • Separating Capital and Capital Gain
    • Offsetting Loans Cost Against Capital Gains
    • Remittance Basis after 7 years
    • Loan from an offshore Trust
    • Working away from the UK
    • Trading As/Ltd Co
    • Gaines -Cooper Implications
    • Family Holding Structure
    • Non-dom buying UK real estate?
    Recent Forum Posts - Old Forums
    • Offsetting Loan cost against capital gains
    • PPR and non-doms
    • Non Dom Remittance
    • Non Dom Remittance
    • Capital Gain Tax
    • Grandparents - Loans to grandchildren
    • Trading ADR's on UK stocks create a remittance?
    • Offshore trust and investments
    • Offshore Directors of UK Company residency status
    • Property to Ltd Company / Linked transactions
    • Capital gains remitted abroad by non-dom
    • Capital Gains Nightmare!!!
    • Election to Offset foreign losses & gains
    • Reducing tax bill on severance payment
    • Becoming non residence after short time in UK
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