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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 contribute to the discussion pages
  4. to search the text or to access it online if you don't have your copy of the book to hand
  5. 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 2009/10 edition

If you wish to buy the 2009/10 edition of Taxation of Foreign Domiciliaries (and so have access to the new online edition) visit http://www.kessler.co.uk/How_to_buy_books_by_James_Kessler.html

To use TFD online 2009/10 you need to register (create an account): if you want to register click here. You will need a copy of the book to register but a free trial subscription is available. Registration for an earlier edition will not be valid for the current edition.

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 in contents, set out below.

Contents of TFD online 2009/10 edition

The initial data was the 2009/10 edition of Taxation of Foreign Domiciliaries with some minor updating. Chapter 38 (Gains of Non-Resident Trusts: Section 87) has been lightly revised, expanding the discussion on transitional rules. Chapter 24 (Offshore Funds from 1 December 2009) has been added.

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


TFD 2008/09 archive edition

An archive edition of TFD online 2008/09 remains online so owners of that edition will still have access to the old edition of TFD online. This will occasionally be useful where it is necessary to research the tax position in 2008/09, 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 of the changes of the FA 2009 operate retrospectively in 2008/09.

Contact

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Technical notes

TFD online is in technical terms a Wiki on the lines of Wikipedia, but only registered users can submit material to this Wiki.


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