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by rr296
Thu Oct 12, 2017 8:55 am
Forum: International Tax
Topic: FX conversion for arising vs remittance basis
Replies: 4
Views: 6615

Re: FX conversion for arising vs remittance basis

For all forms of foreign income paid in Sterling (even if received in foreign currency or converted to foreign currency) - the income amount is fixed in Sterling - similar to chargeable gains Would anyone have to have an original source reference for the above statement by the way? I based my inter...
by rr296
Thu Oct 12, 2017 8:25 am
Forum: International Tax
Topic: FX conversion for arising vs remittance basis
Replies: 4
Views: 6615

Re: FX conversion for arising vs remittance basis

maths wrote:I don't disagree with any of your comments.

As far as I am aware the discussion between HMRC and taxpayers referred to in your final paragraph was never, per se, resolved.


thanks for confirming maths!
by rr296
Tue Oct 10, 2017 3:17 pm
Forum: International Tax
Topic: Remittance basis and US limited partnership investments
Replies: 1
Views: 3658

Re: Remittance basis and US limited partnership investments

The capital accounts are calculated on a US GAAP basis as: capital contributions - distributions + net realised gain (loss) + other portfolio income - operating expenses = capital account at cost + unrealised gain (loss) = capital account at fair value I am wondering if I should look at the capital...
by rr296
Mon Oct 09, 2017 10:43 pm
Forum: International Tax
Topic: ETFs & Shares treated as Interest rather than CG
Replies: 3
Views: 2192

Re: ETFs & Shares treated as Interest rather than CG

Bit late for perhaps still useful I think you are referring to: Non-reporting funds - which is any fund (incl. ETF) that is not a reporting fund. HMRC publish and regularly update a list of all funds that have reporting status. Gains on these are taxed as income (not interest per se but boils down t...
by rr296
Mon Oct 09, 2017 10:34 pm
Forum: International Tax
Topic: Remittance basis and US limited partnership investments
Replies: 1
Views: 3658

Remittance basis and US limited partnership investments

I hold a number of US limited partnership interests for investment purposes. They are proper LPs (not LLCs) and transparent for UK tax purposes. I have been a UK remittance basis tax payer since I first made those investments. Each of the LPs operates as an investment fund that calls capital from ti...
by rr296
Mon Oct 09, 2017 10:15 pm
Forum: International Tax
Topic: FX conversion for arising vs remittance basis
Replies: 4
Views: 6615

FX conversion for arising vs remittance basis

In anticipation of the implementation of the mixed fund cleansing rules later this year (hopefully), I am sorting through the mixed fund spaghetti that I have managed to create over the past years. Quite a lot of those mixed funds are denominated in currencies other than Sterling. My understanding o...
by rr296
Tue Jan 17, 2017 9:16 am
Forum: Savings & Investments, Pensions & Retirement
Topic: Auto-enrolment - unclaimed higher rate relief for prior years
Replies: 1
Views: 287

Auto-enrolment - unclaimed higher rate relief for prior years

My wife is a higher rate tax payer but does not file for self-assessment. Her workplace auto-enrolled her in their pension plan in Aug 2013, with the customary 20% tax relief given at source. She has not claimed the remaining 20% of higher rate relief on this since she was enrolled. After doing some...
by rr296
Wed Jan 11, 2017 1:13 pm
Forum: International Tax
Topic: PPB deemed gain & subsequent full surrender
Replies: 1
Views: 237

PPB deemed gain & subsequent full surrender

After an extended period overseas, I came back to the UK with an insurance bond which turned out to be a PPB (Personal Portfolio Bond). I remain resident to this date. I only realized the consequences of that a few years later, at which point I got the PPB duly endorsed by the insurance company and ...
by rr296
Sun Jan 08, 2017 11:56 pm
Forum: International Tax
Topic: Purchase of Irish ETF listed in London for UK non-dom - remittance risk?
Replies: 3
Views: 443

Re: Purchase of Irish ETF listed in London for UK non-dom - remittance risk?

thanks maths I was thinking that my payment for the ETF shares (most likely) goes into the UK via my offshore bank given that the ETFs are traded by market makers who would typically operate out of London... but upon reflection, I guess that does not matter as those market makers (or more generally ...
by rr296
Sun Jan 08, 2017 2:43 pm
Forum: International Tax
Topic: Purchase of Irish ETF listed in London for UK non-dom - remittance risk?
Replies: 3
Views: 443

Purchase of Irish ETF listed in London for UK non-dom - remittance risk?

I believe the question has been raised a few times over the past 10 years but I have not seen a clear response, so I wanted to ask one more time. I am UK resident but non-dom. I have an offshore bank & brokerage account in Jersey. Through that offshore broker, I am looking to buy a Dublin-domici...

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