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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:

  1. to see if the book has been updated
  2. to correct or contribute to the book
  3. to search the text or to access it online
  4. 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.

  1. Foreign Domicile Tax Reform
  2. Domicile
  3. Residence of Individuals
  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. Savings and Investment Income
  12. Employment Income
  13. Foreign Pensions
  14. Trading Income
  15. Property Income
  16. Settlor-Interested Trusts
  17. Transfer of Assets Abroad - Introduction
  18. Transfer of Assets Abroad - Transferors
  19. Transfer of Assets Abroad - Non-Transferors
  20. Transfer of Assets Abroad - Double Taxation Issues
  21. Transfer of Assets Abroad - Motive Defence
  22. Life Policies and Contracts
  23. Offshore Funds until 1 December 2009
  24. Offshore Funds from 1 December 2009
  25. Accrued Income Profits
  26. Deeply Discounted Securities
  27. Offshore Unit Trusts
  28. Partnerships
  29. Withholding Tax on Interest at Source
  30. Loans from Non-Resident Companies
  31. Non-Residents Income Tax Relief
  32. Collection of Tax from UK Representatives
  33. Investment Manager Exemptions
  34. Rates of Income Tax
  35. National Insurance Contributions
  36. Capital Gains Tax on Individuals
  37. Gains of Non-Resident Trusts: Section 86
  38. Gains of Non-Resident Trusts: Section 87
  39. Gains of Non-Resident Companies
  40. Capital Losses
  41. DT Reliefs for IT and CGT
  42. EU Law Defence to Ant-Avoidance Provisions
  43. Deemed Domicile for IHT
  44. Excluded Property for IHT
  45. Reservation of Benefit
  46. IHT Consequences of Transfers Between Trusts and Adding to Trust Funds
  47. IHT Deduction for Debts
  48. IHT Planning Before and After a Change of Domicile
  49. IHT on Death: Wills and IoVs
  50. IHT Pre 1975 Double Tax Treaties
  51. US IHT Treaty
  52. IHT Unilateral Relief
  53. UK Domiciliary Married to Foreign Domiciliary
  54. The Family Home
  55. Pre-Owned Assets
  56. Estates of Deceased Persons - CGT
  57. Estates of Deceased Persons - IT
  58. Who is the Settlor?
  59. Situs of Assets for IHT
  60. Situs for Assets for CGT
  61. Disclosure & Compliance
  62. Categorisation of Foreign Entities
  63. Control Connected Close and Related Expressions
  64. Permanent Establishment and Branch/Agency
  65. New_Chapter_Foreign_Currency_Issues
  66. Appendix 1 Terminology
  67. Appendix 2 Baker and Garland Trust Jurisdictions
  68. 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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