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"Taxation of Foreign Domiciliaries 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

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

To use TFD online you need to register (create an account). You will need a copy of the current (2011/12) edition to register. 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 or download a paper order form.

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

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.

The Swiss Tax Agreement 2011

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

Contents of TFD online 2011/12 edition

The initial data was the 2011/12 edition of Taxation of Non-residents and Foreign Domiciliaries. However chapter 46 (Borrowing by trustees: sch 4B and especially the discussion on sch 4C TCGA) has been revised in the light of further work in this area after going to print.

Introduction

1 Foreign Domicile Tax Reform
2 Domicile
3 Residence of Individuals
3A Residence of Individuals from 2012- 2013
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 Mixed Funds
12 Employment Income
13 Trading Income
14 Property Income
15 Deduction of Interest in Computing Property Income
16 Savings and Investment Income
17 Interest Income
18 Exempt Interest of Non-Residents
19 Dividends and Distributions
20 Royalties
21 Pension Income
22 Discretionary Trusts
23 IP Trusts - Income Tax
24 Settlor-Interested Trusts
25 Transfer of Assets Abroad - Introduction
26 Transfer of Assets Abroad Transferors
27 Transfer of Assets Abroad - Non-Transferors
28 Transfer of Assets Abroad - Double Taxation Issues
29 Transfer of Assets Abroad - Motive Defence
30 Life Policies and Contracts ("Bonds")
31 Offshore Funds - Definitions
32 Offshore Funds - Taxation
33 Accrued Income Profits
34 Deeply Discounted Securities
35 Unit Trusts
36 Partnerships
37 Non-Residents Income Tax Relief
38 Collection of Tax from UK Representatives
39 Investment Manager Exemptions
40 Loans from Non-Resident Companies
41 Rates of Tax and Personal Allowances
42 National Insurance Contributions
43 Capital Gains Tax on Individuals
44 Gains of Non-Resident Trusts: Section 86
45 Gains of Non-Resident Trusts: Section 87
46 Borrowing by Non-Resident Trust: Sch 4B TCGA
47 Gains of Non-Resident Companies
48 Capital Losses
49 Foreign Currency Issues
50 DT Reliefs for IT and CGT
51 EU Law Defence to Ant-Avoidance Provisions
52 Deemed Domicile for IHT
53 Excluded Property for IHT
54 Reservation of Benefit
55 IHT Consequences of Transfers Between Trusts
56 IHT Deduction for Debts
57 IHT Planning Before and After a Change of Domicile
58 IHT on Death: Wills and IoVs
59 Double Inheritance Taxation - Introduction
60 IHT DTTs India, Pakistan, Italy, France
61 IHT DTT USA
62 IHT DTA: Switzerland
63 Foreign IHT Credit Relief
64 UK Domiciliary Married to Foreign Domiciliary
65 The Family Home and its Chattels
66 Pre-Owned Assets
67 Estates of Deceased Persons - CGT
68 Estates of Deceased Persons - IT
69 Who is the Settlor?
70 Situs of Assets for IHT
71 Situs for Assets for CGT
72 Categorisation of Foreign Entities
73 Control Connected Close and Related Expressions
74 Permanent Establishment and Branch/Agency
75 Disclosure & Compliance
App 1 Appendix 1 Terminology
App 2 Appendix 2 Members of Parliament
App 3 Appendix 3 Visiting Forces
App 4 Appendix 4 Students
Table of Abbreviations


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 online 2008/09, TFD online 2009/10 and TFD online 2010/11. 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 thoughts 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 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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