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About TFD online

TFD online is a free service for individuals and firms who have purchased the current edition of 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.

To use it you need to register: if you want to register click here

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.

TFD online is moderated by Amanda Hardy

Frequently asked questions are available

Contents of TFD online

The initial data was the 2008/09 edition of Taxation of Foreign Domiciliaries. Chapter 9 (meaning of remittance) has subsequently been rewritten, in the light of further work done up to November 2008. Readers of the book may find it useful to print this out and use it in place of the chapter as printed in the book. That was just a first sketch of the vast range of issues raised by the new legislation which the revised chapter seeks to address in more detail. Chapter 22 (offshore funds) has also been rewritten in the light of further work done up to May 2009.

Changes should be recorded in the history section of each page.

1. Reform of Foreign Domiciliary Tax
2. Domicile
3. Residence of Individuals
4. Residence of Trustees
5. Year of Arrival and Departure
6. Exit Taxes
7. Temporary Non-residence
8. Remittance Basis
9. Meaning of Remittance
10. Savings and Investment Income
11. Employment Income
12. Foreign Pensions
13. Trading Income
14. Property Income
15. Settlor-interested Trusts
16. Transfer of Assets Abroad: Introduction
17. Transfer of Assets Abroad: Transferors
18. Transfer of Assets Abroad: Non-transferors
19. Transfer of Assets Abroad: Double Taxation Issues
20. Transfer of Assets Abroad: Motive Defence
21. Life Policies and Contracts (“Bonds”)
22. Offshore Funds
23. Accrued Income Profits
24. Deeply Discounted Securities
25. Offshore Unit Trusts
26. Offshore partnerships
27. Withholding Tax on Interest
28. Loans from Non-resident Companies
29. Collection of tax from UK representatives
30. Limit of liability of Non-residents
31. Rates of Income Tax
32. National Insurance Contributions
33. Capital Gains Tax on Individuals
34. Capital Gains Tax: s. 86 TCGA
35. Capital Gains Tax: s. 87 TCGA
36. Gains of non resident companies
37. Capital losses
38. DT reliefs and anti avoidance provisions
39. EU defence to anti-avoidance provisions
40. Deemed domicile for IHT
41. Excluded Property for IHT
42. Reservation of Benefit
43. IHT Consequences of Transfers Between Trusts
44. IHT Deduction for Debts
45. IHT Planning Before and After a Change of Domicile
46. IHT on Death: Wills and IOVs
47. IHT Double Tax Reliefs
48. IHT USA Double Taxation Treaty
49. UK Domiciliary Married to Foreign Domiciliary
50. The Family Home and its Chattels
51. Pre-Owned Assets
52. Estates of Deceased Persons: CGT
53. Estates of Deceased Persons: Income Tax
54. Who is the Settlor?
55. Situs of Assets for IHT
56. Situs of Assets for CGT
57. Duties of Disclosure
58. Categorisation of Foreign Institutions

• Appendix 1. Terminology
• Appendix 2. Baker and Garland Trust Jurisdictions

Contact

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Technical notes

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