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TFD Online is the online version of the book Taxation of Non-Residents and Foreign Domiciliaries by James Kessler QC. TFD online is concerned with:

1. Taxation of foreign domiciliaries
2. Taxation of non-residents on UK income and assets
3. Taxation of UK residents on foreign income and assets

Users can also correct or contribute to the text and if you see anything that needs correcting or expanding, please do! A free copy of the next edition of the book will be given to the user who makes the most edits. Online corrections are reviewed by Amanda Hardy.

To use TFD online you need to register (create an account). You need a copy of the current edition of the book to register. If you registered before the current edition was published in September 2012, you will need to reregister with the password in the current edition. Registration for an earlier edition will not be valid. But if you have not (yet) bought the book you may still register for a free one day trial.

To order the book, go to the publishers online ordering and search for Kessler.

If you have registered, login here – once logged in you can search or navigate by clicking on a chapter heading below.

Contents of TFD online 2012/13 edition

The initial data was the 2012/13 edition of Taxation of Non-residents and Foreign Domiciliaries though there has been a small amount of updating after going to print.

Introduction

1 Foreign Domicile Tax Reform

2 Domicile

3 Residence of Individuals

3A Residence of Individuals from 2013- 2014

4 Residence of Trustees

5 Treaty-Residence

6 Year of Arrival and Departure

7 Exit Taxes

8 Temporary Non-residence

9 Remittance Basis

10 Meaning of Remittance

11 Remittance Reliefs

12 Mixed Funds

13 Employment Income

14 PAYE

15 Trading Income

16 Property Income

17 Deduction of interest in computing property income

18 Savings and Investment Income

19 Interest Income

20 Exempt Interest of Non-Residents

21 Dividends and Distributions

22 Royalty Income

23 Pension Income

24 Discretionary Trusts: Income Tax

25 IP Trusts: Income Tax

26 Settlor-interested Trusts

27 Transfer of Assets Abroad: Introduction

28 Transfer of Assets Abroad: Transferors

29 Transfer of Assets Abroad: Non-transferors

30 Transfer of Assets Abroad: Double Taxation Issues

31 Transfer of Assets Abroad: Motive Defence

32 Life Policies and Contracts

33 Offshore Funds - Definition

34 Offshore Funds - Taxation

35 Accrued Income Profits

36 Deeply Discounted Securities

37 Unit Trusts

38 Partnerships

39 Non-Residents Income Tax Relief

40 Collection of Tax from UK Representatives

41 Investment Manager Exemptions

42 Loans from Non-Resident Companies

43 Rates of Tax

44 Personal Allowances

45 National Insurance Contributions

46 Capital Gains of UK Residents

47 Gains of Non-Resident Settlor-Interested Trusts: s.86

48 Capital Payments from Non-Resident Trusts: s.87

49 Borrowing by Non-resident Trust: Sch 4B TCGA

50 Gains of Non-Resident Companies

51 Capital Losses

52 Foreign Currency Issues

53 Double Taxation Agreements: Introduction

54 Foreign Tax Credit Relief

55 DTAs: Interaction with UK tax legislation

56 EU Law and UK Taxation

57 Deemed Domicile for IHT

58 Excluded Property for IHT

59 Reservation of Benefit

60 IHT Consequences of Transfers Between Trusts

61 IHT Deduction for Debts

62 IHT Planning Before and After a Change of Domicile

63 IHT on Death: Wills and IOVs

64 Double Inheritance Taxation: Introduction

65 IHT DTTs India, Pakistan, Italy, France

66 IHT DTT USA

67 IHT DTT Switzerland

68 Unilateral Foreign IHT Credit

69 UK Domiciliary Married to Foreign Domiciliary

70 The Family Home and its Chattels

71 Joint Accounts

72 Pre-Owned Assets

73 Estates of Deceased Persons: CGT

74 Estates of Deceased Persons: IT

75 Who is the Settlor?

76 Trusts with Two or More Settlors

77 Situs of Assets for IHT

78 Situs of Assets for CGT

79 Foreign Entities

80 Control Connected Close and Related Expressions

81 Permanent Establishment & Branch/Agency

82 Disclosure and Compliance

Appendix 1: Some Common Statutory Terms

Appendix 2: Construction of Deeming Provisions

Appendix 3: Members of Parliament

Appendix 4: Visiting Forces

Appendix 5: Students

Appendix 6: How to Improve Residence and Domicile Taxation

[[1]] Table of Cases

[[2]] Table of Statutes

[[3]] Table of Statutory Instruments

[[4]] Table of EU and Foreign Statutes and international Conventions

[[5]] Table of HMRC Concessions and Statements

[[6]] Table of HMRC Manuals

[[7]] Table of Double Tax Treaties

Table of Abbreviations

The Swiss Tax Agreement 2011

TFD online does not consider the new Swiss Tax Agreement, but this topic is discussed in James Kessler's ebook The Swiss Tax Agreement 2011 available from Key Haven Publications. This is up to date as at 12 December 2011.

If you need further advice

If you do not find the answer to your question in TFD online, or if you need advice on which you can legally rely, you may instruct James Kessler QC to advise. For further information see How to instruct James Kessler QC.

TFD archive editions

There are online archive editions for TFD 2008/09, TFD 2009/10 TFD 2010/11, and TFD 2011/12 These will occasionally be useful to investigate the tax position in those years, but the current edition will generally be the best starting point, as that has been substantially rewritten in the light of current HMRC guidance and further thought and research.

Contact

If you have technical problems, click here

To contact James Kessler QC click here

To contact Amanda Hardy, who reviews online corrections, click here

To contact the publishers of Taxation of Non-Residents and Foreign Domiciliaries click here

For multiple user licences, or to install on a firm's intranet, contact the publishers.

Technical notes

TFD online is in technical terms a Wiki on the lines of Wikipedia, but it is only open to registered users.

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