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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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