Non-domiciliaries and the remittance basis

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Practice notes
The term 'relevant property' defines a category of trust property which is subject to a special regime for inheritance tax (IHT). As described in...
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Produced in partnership with Paul Davies of Clarke Willmott 12th Jan
Practice notes
On the face of it, there would appear to be no specific impediment, if there is no reason to suppose that a person is without capacity, in them...
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9th Nov
Practice notes
Offshore income gains (OIGs) are gains realised on the disposal of interests in offshore funds which are either:•non-distributor offshore funds, or...
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9th Nov
Practice notes
A trust is formed either by lifetime gift or on death when a person (the settlor) transfers assets to another person or persons (the trustees) to hold...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
When trustees are engaged in trust litigation, issues often arise as to how their litigation costs are to be funded. A Beddoe application is the best...
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Produced in partnership with Kate Davenport QC of Outer Temple Chambers and Adele Isaacs of Bankside Chambers 12th Jan
Practice notes
This Practice Note outlines Bermuda trust law and focuses upon its unique features and recent reforms, such as Bermuda's regime for private trust...
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Produced in partnership with Vanessa Lovell Schrum and Caljonah Smith of Appleby, Bermuda 12th Jan
Practice notes
This Practice Note provides guidance on Cayman Islands STAR trusts. For general information about the Cayman Islands, see Practice Note: Private...
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Produced in partnership with Mourant Ozannes and Carey Olsen 12th Jan
Practice notes
Trust litigation has been classified as being of three types:•a dispute as to the trusts on which trustees hold the subject matter of the settlement•a...
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9th Nov
Practice notes
Where a beneficiary either:•is a minor (ie under the age of 18) and unmarried or•has attained majority or has married under that date but is required...
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9th Nov
Practice notes
Duration of a trustThe duration of an express trust is subject to the restrictions imposed by the rules against remoteness of vesting and against the...
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9th Nov
Practice notes
Duty to distribute to the correct beneficiariesOn the termination of the trust, the trustees are under a duty to distribute the trust assets to the...
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9th Nov
Precedents
This Deed of Appointment is made on [date] by [trustee] of [address] and [trustee] of [address] (the Trustees).Background(A)This Deed is supplemental...
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9th Nov
Practice notes
When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets...
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9th Nov
Practice notes
Liferent trustsA liferent trust (or trust liferent) is a trust which, when settled, confers a use and income benefit, or both, in the trust property...
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Produced in partnership with Peter Murrin of Turcan Connell 12th Jan
Practice notes
An offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK inheritance tax (IHT) is not dependent on the...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 12th Jan
Practice notes
Express creation of trustsA trust is constituted expressly where the owner of property (the truster) transfers property to trustees to hold for...
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Produced in partnership with Yvonne Evans, Law Lecturer, Solicitor (non-practising), TEP, University of Dundee 12th Jan

Most recent Non-domiciliaries and the remittance basis content

Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.One of the features of the UK employment income tax rules has long been to afford...
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Produced in partnership with Darren Oswick of Simmons & Simmons 9th Apr
Practice notes
Transfer of Assets Abroad CodeThe anti-avoidance provisions relating to a transfer of assets abroad are contained in Chapter 2, Part 13 of the Income...
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9th Apr
Practice notes
This Practice Note is an overview of the issues facing non-UK domiciliaries when purchasing a home in the UK with a mortgage. The use of debt to fund...
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9th Apr
Practice notes
FORTHCOMING CHANGES: At Spring Budget 2020, the government announced plans (following a consultation) to introduce (from 1 April 2021) an additional...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 9th Apr
Practice notes
To determine whether a remittance has occurred for the purposes of the remittance basis of taxation, reference must be made to the Conditions set out...
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Produced in partnership with Clare Ludlam and Nick Warr of Taylor Wessing LLP 9th Apr
Practice notes
When you advise an individual on cross-border issues or offshore tax planning, it is important to establish the 'situs' (ie location) of the assets...
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9th Apr
Practice notes
Overseas Workday Relief (OWR) is a relief from UK income tax for certain non-domiciled individuals, who have elected to be taxed on the remittance...
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Produced in partnership with Lisa Spearman of Mercer & Hole 9th Apr
Practice notes
FORTHCOMING CHANGES: At Spring Budget 2020, the government announced plans (following a consultation) to introduce (from 1 April 2021) an additional...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 9th Apr
Practice notes
When advising an individual on cross-border or offshore tax planning, it is important to establish the 'source' of income received by or for the...
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9th Apr
Practice notes
The concepts of residence and domicile are used to establish the extent of an individual's liability to UK taxation. This Practice Note provides a...
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9th Apr
Practice notes
This Practice Note considers the particular capital loss election that can be made by non-domiciled individuals who claim the remittance basis. For an...
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9th Apr
Practice notes
A remittance of an individual’s income or chargeable gains will occur if Conditions A and B are met (or if one of Conditions C and D are...
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Produced in partnership with Clare Ludlam and Nick Warr of Taylor Wessing LLP 9th Apr
Practice notes
At Summer Budget 2015, the government announced wide-ranging reforms to the deemed domicile rules and also to the excluded property rules as they...
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9th Apr
Practice notes
An offshore trust is any non-UK resident trust. The liability of trustees of an offshore trust to UK inheritance tax (IHT) is not dependent on the...
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Produced in partnership with Jenny Wilson-Smith and Emma Haley of Boodle Hatfield 9th Apr
Practice notes
ARCHIVED: This Practice Note has been archived and is not maintained.The incidence of inheritance tax (IHT) depends on the domicile of an individual....
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9th Apr
Practice notes
FORTHCOMING CHANGE: As announced at Budget 2018, draft legislation to be included in Finance Bill 2019–20 was published on 11 July 2019 and includes a...
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Produced in partnership with Alison Cartin of Taylor Wessing LLP 9th Apr
Practice notes
Individuals using the remittance basis of taxation should be advised to set up foreign accounts correctly and to use them carefully. This Practice...
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9th Apr
Practice notes
Individuals who are resident and domiciled, or deemed domiciled, in the UK are liable to pay UK income tax on their worldwide income and UK capital...
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Produced in partnership with Clare Ludlam and Nick Warr of Taylor Wessing LLP 9th Apr
Practice notes
AAdministrationThe process starting on the date of the deceased's death and ending on the date the deceased's affairs are finalised by his personal...
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9th Apr
Practice notes
UK resident non-domiciliaries who are taxed on the remittance basis will not be taxed on foreign income or gains until or unless they are remitted to...
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9th Apr

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