Taxation of Non-Residents and Foreign Domiciliaries (online) 19th Edition 2020/21
Online Version
Author: James Kessler QC
ISBN: 978-1-901614-81-7
Publication date: 06/04/2020
Price: £384.00
Taxation of Non-Residents and Foreign Domiciliaries
19th Edition 2020/21
Author: James Kessler QC
Publication date:
For TFD Online 01/05/2019
ISBN: 978-1-901614-81-7
For TFD hard copy, see below
ISBN978-1-901614-82-4
Three purchasing options
Online access only £384.00 plus VAT (£460.80 inc) for annual single user access.
Hard Copy only Publication Price £384.00 (for all seven volumes of the edition).
Hard copy plus annual single user online access £570.00
(Comprises: Book £384.00 - Licence £155.00 - Total £539.00)
Multiple licences and hardcopies are available on application.
The online subscription for 19th Edition of online TFD runs from April 1st 2020 for 12 months. The subscription period will end on March 31st 2021. This edition was initially based on the Finance Bill as published on March 17th 2020 and updated subsequently as necessary. The hard copy, which will not be produced until Finance Act 2020 has become law, is likely to be published in early June 2020.
For Enquiries contact aw.khpplc@khpplc.co.uk
or visit
Contents include the most thorough analysis ever published of:
Taxation of foreign domiciliaries
Taxation of non-residents on UK income and assets
Taxation of UK residents on foreign income and assets
The author
James Kessler QC is head of Old Square Tax Chambers.
James advises in particular on foreign domiciliaries, offshore and onshore trusts, wills and charities. Other areas of practice include prosecution of tax crime in complex cases, particularly along the avoidance/evasion faultline, and freedom of information.
James is one of the founders of the Society of Trust and Estate Practitioners, for whom he drafted the STEP Standard Provisions, and a fellow of the Chartered Institute of Taxation.
James has received the Shindler Award for Outstanding Contribution to the Profession.
Contents of the 19th Edition
1. Foreign Domicile: Tax Policy
2. Tax Avoidance
3. Domicile
4. Deemed Domicile
5. Residence of Individuals
6. Residence of Trustees
7. Treaty-Residence
8. Exit Taxes
9. Split Years: Arrival and Departure
10. Temporary Non-residence
11. Source/Relevant Foreign Income
12. The Remittance Basis
13. The Meaning of Remittance
14. Remittance Reliefs
15. Mixed Funds
16. Trading Income
17. Trading in Land
18. Performers
19. Property Income
20. Deduction of Interest from Property Income
21. Interest Income
22. Exempt Interest of Non-Residents
23. Dividend Income
24. Royalty Income
25. Misc Sweep-Up Income
26. Employment Income
27. Travel Expenses: Employment Income
28. PAYE
29. Employment Income: DT Relief
30. Pension and Annuity Income
31. Discretionary Trusts: Income Tax
32. IIP Trusts: Income Tax
33. Settlor-Interested Trust Code
34. Transfer of Assets Abroad: Introduction
35. Transfer of Assets Abroad: Transferors
36. Transfer of Assets Abroad: Benefits
37. Transfer of Assets Abroad: Relief From Overlapping Charges
38. Transfer of Assets Abroad: Motive Defence
39. Profit Fragmentation
40. Transfer of Income Stream
41. Life Policies and Contracts
42. Offshore Funds: Definitions
43. Offshore Income Gains
44. Income from Offshore Funds
45. Accrued Income Profits
46. Deeply Discounted Securities
47. Unit Trusts
48. Intermediated Securities
49. Partnerships
50. Non-Residents Income Tax Relief
51. Collection of Tax from UK Representatives
52. Investment Manager Exemptions
53. Investment Management Fees & Carried Interest
54. Loans from Non-Resident Companies
55. Transactions in Securities
56. Rates of Income Tax/CGT
57. Personal Allowances
58. National Insurance Contributions
59. Chargeable Gains
60. UK Property held by Non-residents
61. Private Residence Relief
62. Gains of Non-Resident Settlor-Interested Trusts: s.86
63. Capital Payments from Non-Resident Trusts: s.87
64. Borrowing by Non-resident Trusts: Sch 4B
65. Protected Trust
66. Sub-Funds
67. Gains of Non-Resident Companies
68. Capital Losses
69. Foreign Currency Issues
70. Unremittable Assets
71. Double Taxation Arrangements: Introduction
72. DTA Anti-Abuse Rules
73. Limitation on Benefits
74. Foreign Tax Credit Relief
75. EU Law and UK Taxation
76. Excluded Property: Definition
77. Excluded Property Exemptions
78. Wills and IOVs
79. Reservation of Benefit
80. Inter-Trust Transfers: IHT
81. IHT Deduction for Debts
82. IHT Close-company Code
83. IHT Double Taxation Treaties: Introduction
84. IHT DTAs: India, Pakistan, Italy, France
85. IHT DTA: Netherlands
86. IHT DTA: South Africa
87. IHT DTA: Switzerland
88. IHT DTA: USA
89. Foreign IHT Credit Relief
90. IHT Residential Property Code
91. Family Home and Chattels: Benefit in Kind Charges
92. Pre-Owned Assets
93. Non-Dom/Non-Resident Spouse
94. Joint Accounts
95. ATED Taxes
96. Estates of Deceased Persons: CGT
97. Estates of Deceased Persons: Income Tax
98. Who is the Settlor?
99. Trust with Two or More Settlors
100. Situs of Assets for IHT
101. Situs of Assets for CGT
102. Foreign Entities
103. Hybrid Entities
104. Control, Connected, Close and Related Expressions
105. Permanent Establishment and Branch/Agency
106. Reporting and Compliance
107. Claims
108. Reporting and Compliance: IHT
109. Reporting Beneficial Owners
110. Reporting Offshore Trusts
111. Requirement to Correct
112. Criminal Law and Professional Conduct
Appendix 1: Words of Dispute
Appendix 2: Common Legal Expressions
Appendix 3: Family Terminology
Appendix 4: Consideration, Arm's Length, Full Value
Appendix 5: Commercial/View to Profit
Appendix 6: Associated Operations: IHT
Appendix 6: Associated Operations: IHT
Appendix 7: Deeming Provisions
Appendix 8: The Territorial Principle
Appendix 9: What do we mean by “Real”?
Appendix 10: Parliamentarians
Appendix 11: Visiting Forces
Appendix 12: How to Improve Residence and Domicile Taxation
Appendix 13: Reform of Offshore Anti-Avoidance Law
Appendix 14: UK Arrival or Departure: Tax Checklist
Appendix 15: The Wisdom of Parliament