- Major Reform of the Capital Gains Tax Regime effective from 6 April next (February 2008)
As has been widely discussed in the national press, the capital gains tax regime is to be simplified with effect from 6 April 2008...READ MORE
- Non-Domiciliaries Face Harsh Tax Regime (January 2008)
The long awaited draft legislation is respect of the taxation of non-domiciliaries claiming the remittance basis was published early in January and it has proved to be much more tightly drawn than was expected...READ MORE
- New Provisions to Counteract Income Shifting (December 2007)
Having been defeated in the House of Lords in the Arctic Systems case, HMRC announced immediately afterwards that it would bring forward new legislation with the broad effect of reinstating the tax position which it argued for in that case...READ MORE
- All change for non-domiciliaries? (November 2007)
Those resident in the United Kingdom but not domiciled here received a shock in the Pre-Budget Report this autumn in which proposals were announced which effectively mean the withdrawal next year of the remittance basis of taxation for those who have been resident in the United Kingdom for more than seven years. All but the very wealthy can escape, and they would do so by paying what amounts to an 'entry fee' of £30,000 per annum to enable them to continue with taxation on the present basis...READ MORE
- Another budget bombshell!! (October 2007)
The annual budget in March 2006 introduced such far reaching capital tax changes
that taxpayers might have hoped to have a respite for quite a while from further
shocks of that type. Unfortunately yet more unexpected changes of wide impact
were announced in the Pre Budget Report in October this year, just over two months
after the 2007 Finance Act received the Royal Assent, so taxpayers clearly need to
be prepared for the unexpected at any time...READ MORE
- Let property as a business (September 2007)
A fascinating news story was widely reported in the daily press in recent weeks concerning a couple who had taken up residence at a Travelodge hotel. Apparently they moved in many years ago and enjoyed the life of having their room cleaned for them and their meals cooked in a nearby restaurant that they decided to stay on a long term basis...READ MORE
- Rectifying a faulty deed (August 2007)
Mistakes in legal documentation are certainly not unknown but rectifying them can be quite a troublesome matter. Once a document has been signed as a deed by all parties and dated, it has full legal effect and it is treated as accurately setting out the intentions of the parties. If in fact it does not, the question then arises as to what can be done about it...READ MORE
- Arctic Systems: do not spend too long celebrating! (July 2007)
Now this is not the end. It's not even the beginning of the end, but it is perhaps the end of the beginning! Those celebrated words of Churchill aptly sum up where we are with Arctic Systems. The taxpayers have won in the House of Lords but much more is yet to be heard on this topic. HM Revenue & Customs have already said that they will bring forward proposals to change the law and discussions on this will take place....READ MORE
- Pre-owned assets following the Finance Bill 2007 (June 2007)
The Finance Act 2004 introduced the legislation relating to pre-owned assets which was broadly designed to collect some tax on an annual basis from those who had successfully avoided the gift with reservation provisions for inheritance tax...READ MORE
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Tax case makes the headlines (May 2007)
It is not often that a decision of the Special Commissioners makes the main news story in the daily press, but the decision in Phizackerley v HMRC did exactly that a short time ago. As the news reports betrayed a complete misunderstanding of the case (including blaming it on Gordon Brown as a new stealth tax!), we will explain here what the case was really all about and what the true significance of it was.....READ MORE
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Pre-owned assets: Budget update (April 2007)
The annual income tax charge on 'pre-owned assets' was introduced in the Finance Act 2004 and this was designed to either collect tax each year from all those who had previously entered into inheritance tax planning schemes or alternatively force them to unwind the schemes thereby reinstating the inheritance tax liability.....READ MORE
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Wills, trusts and estates post Finance Act 2006 (March 2007)
The Finance Act 2006 has completely destroyed the careful structure of the
previous inheritance tax provisions relating to trusts. In doing so, it introduced
a dichotomy between trusts set up under wills and those set up in lifetime,
with a further subdivision for trusts set up by a parent under a will and those
set up by some other relative by will....READ MORE
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Unscrambling inheritance tax schemes (February 2007)
Many inheritance tax schemes have become uneconomic following the introduction of pre-owned asset tax. For example, a popular scheme at one time was the ‘Ingram’ scheme in relation to the main residence; this involved the taxpayer keeping a leasehold interest in the residence and giving away the freehold to his or her children or to a trust for them....READ MORE
- Revenue practice on residence (January 2007)
A recent case before the Special Commissioners concerning the residence and domicile of a taxpayer has caused sufficient shock to be widely discussed in the columns of the money pages of weekend newspapers....READ MORE
