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From TFD Online 2009-10
About TFD online
TFD online is a free service for individuals and firms who have purchased the book Taxation of Foreign Domiciliaries by James Kessler QC.
TFD online can be used:
- to see if the book has been updated
- to correct or contribute to the book
- to search the text or to access it online
- to have a quick look to see if you want to buy the book.
TFD online is moderated by Amanda Hardy. Frequently asked questions are available
TFD 2010/11 edition forthcoming soon
The new 2010/11 edition of "Taxation of Foreign Domiciliaries" will be published on 6 September 2010. To maintain unbroken access to TFD online you will need to order a copy of the new edition.
To order the book, please go to the publishers online ordering. Alternatively download a paper order form. For reviews click here.
To use TFD online you need to register (create an account): to register click here. You will need a copy of the current edition to register but a free trial subscription is available. Registration for an earlier edition will not be valid for the current edition. If you do not have a copy of the 2009/10 edition you may either order the new edition and wait for it to come out or (if you cannot wait) you may wish to purchase the current and forthcoming editions together from the publishers at a package price (50% off the price of the current edition as it now has a short shelf life.) To accept this offer contact the publishers
If you have registered, login here – once logged in you can return to this page and then search or go where you want by clicking on one of the chapters set out below.
Contents of TFD online 2009/10 edition
The initial data was the 2009/10 edition of Taxation of Foreign Domiciliaries with minor updating. Chapter 38 (Gains of Non-Resident Trusts: Section 87) has been lightly revised, expanding the discussion on transitional rules. Two chapters have been added: Chapter 24 (Offshore Funds from 1 December 2009) and a new chapter on Foreign Currency Issues.
It will be necessary to refer to the printed book to follow a few of the longer tables. Changes should be recorded in the history section of each page.
- Foreign Domicile Tax Reform
- Domicile
- Residence of Individuals
- Residence of Trustees
- Treaty-Residence
- Year of Arrival and Departure
- Exit Taxes
- Temporary Non-Residence
- Remittance Basis
- Meaning of Remittance
- Savings and Investment Income
- Employment Income
- Foreign Pensions
- Trading Income
- Property Income
- Settlor-Interested Trusts
- Transfer of Assets Abroad - Introduction
- Transfer of Assets Abroad - Transferors
- Transfer of Assets Abroad - Non-Transferors
- Transfer of Assets Abroad - Double Taxation Issues
- Transfer of Assets Abroad - Motive Defence
- Life Policies and Contracts
- Offshore Funds until 1 December 2009
- Offshore Funds from 1 December 2009
- Accrued Income Profits
- Deeply Discounted Securities
- Offshore Unit Trusts
- Partnerships
- Withholding Tax on Interest at Source
- Loans from Non-Resident Companies
- Non-Residents Income Tax Relief
- Collection of Tax from UK Representatives
- Investment Manager Exemptions
- Rates of Income Tax
- National Insurance Contributions
- Capital Gains Tax on Individuals
- Gains of Non-Resident Trusts: Section 86
- Gains of Non-Resident Trusts: Section 87
- Gains of Non-Resident Companies
- Capital Losses
- DT Reliefs for IT and CGT
- EU Law Defence to Ant-Avoidance Provisions
- Deemed Domicile for IHT
- Excluded Property for IHT
- Reservation of Benefit
- IHT Consequences of Transfers Between Trusts and Adding to Trust Funds
- IHT Deduction for Debts
- IHT Planning Before and After a Change of Domicile
- IHT on Death: Wills and IoVs
- IHT Pre 1975 Double Tax Treaties
- US IHT Treaty
- IHT Unilateral Relief
- UK Domiciliary Married to Foreign Domiciliary
- The Family Home
- Pre-Owned Assets
- Estates of Deceased Persons - CGT
- Estates of Deceased Persons - IT
- Who is the Settlor?
- Situs of Assets for IHT
- Situs for Assets for CGT
- Disclosure & Compliance
- Categorisation of Foreign Entities
- Control Connected Close and Related Expressions
- Permanent Establishment and Branch/Agency
- New_Chapter_Foreign_Currency_Issues
- Appendix 1 Terminology
- Appendix 2 Baker and Garland Trust Jurisdictions
- Appendix 3 Mixed fund rules before 2008/09
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 entitled to rely, you may instruct James Kessler QC to advise. For further information see How to instruct James Kessler QC.
TFD archive editions
An archive edition of TFD online 2008/09 remains online and the 2009/10 edition will move to an archive when the new edition is published. These will occasionally be useful where it is necessary to investigate the tax position in earlier years, but the up to date edition will generally be the best starting point, as that has been very substantially rewritten in the light of HMRC guidance, further thoughts, and several changes of the FAs 2009 and 2010 operate retrospectively.
Contact
If you have technical problems, click here
To contact the moderator click here
To contact James Kessler QC click here
To contact the publishers of Taxation of Foreign Domiciliaries click here
For multiple user licences, please 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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