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Where Taxpayers and Advisers Meet

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by Taxbar
Tue May 18, 2010 3:57 pm
Forum: International Tax
Topic: UK/India Estate Tax Treaty
Replies: 2
Views: 2078

Re: UK/India Estate Tax Treaty

Dear Sirp2000, You ask what steps need to be taken to ensure an Indian Domicile is maintained? Apart from careful drafting of wills, there are a number of steps which really need specific advice (and outside the scope of a forum reply); as well as an initial written opinion on your Client's Domicile...
by Taxbar
Tue May 18, 2010 3:42 pm
Forum: International Tax
Topic: Proving non-UK residency
Replies: 2
Views: 1506

Re: Proving non-UK residency

Dear Ian, HMRC's specialist unit:- Centre For Non residents (CNR) have a clear policy of attacking Pilots on their residency position and have investigated several hundred in the last few years. There efforts culiminated in the Shepherd and Grace cases, where both Pilots were effectively held to be ...
by Taxbar
Thu Dec 17, 2009 1:43 pm
Forum: International Tax
Topic: is this a remittance?
Replies: 7
Views: 2054

Re: is this a remittance?

Dave, The situation you describe is as Maths says, confused. Do you not carry out some duties of your employment in the UK? HMRC are unlikely to believe that you do not. Are you connected by ownership or control with the Offshore Employer? I suspect you need an apportionment of income between UK and...
by Taxbar
Wed Dec 09, 2009 1:21 pm
Forum: International Tax
Topic: Dad's offshore - can he pay my mortgage off?
Replies: 2
Views: 1292

Re: Dad's offshore - can he pay my mortgage off?

Dear Macallan, The first issue is where your Dad is tax resident and what the local laws are regarding gifts etc? Assuming that he is clearly not UK resident and there are no adverse tax consequences in his Country of residence; then we have to consider UK tax. Although, he maybe non-UK resident, Da...
by Taxbar
Tue Dec 01, 2009 5:20 pm
Forum: General
Topic: company loan to directors
Replies: 4
Views: 1255

Re: company loan to directors

Dear Paul, the loan will be within section 419(1) ICTA 1988. The only way to avoid this is if the Company is a money lending business and the loan is "in the ordinary course of a business carried on by it which includes the lending of money". See Brennan v Denby Investment Co Ltd (2001) as to what c...
by Taxbar
Fri Nov 27, 2009 5:04 pm
Forum: International Tax
Topic: Domicile
Replies: 9
Views: 2781

Re: Domicile

Barry, Since HMRC stopped giving rulings on Domicile you will need a proper legal opinion and that is now the starting point for most new Domicile claimants. HMRC will give some weight to a well drafted legal opinion that considers the clients personal cirucmstances and the law in this area. There h...
by Taxbar
Fri Nov 27, 2009 4:44 pm
Forum: International Tax
Topic: International Property Company
Replies: 5
Views: 1564

Re: International Property Company

The so-called tax planning you have mentioned is tax evasion and not avoidance. If the commissions are generated from your work and you are resident and domiciled here, then by assigning those commissions to a foreign Company and not declaring that income you would be caught by Sections 720 and 727 ...
by Taxbar
Tue Nov 17, 2009 12:54 pm
Forum: International Tax
Topic: Capital Gains non resident US citizen
Replies: 4
Views: 1502

Re: Capital Gains non resident US citizen

Actually there is another UK tax exposure. If you pass away holding UK stocks and shares you could have a UK Inheritance tax exposure, unless protected by the US/UK Estate tax treaty Article 5 .This should work for most UK stocks and shares. However, there will still be need for a UK probate using y...
by Taxbar
Tue Nov 17, 2009 12:20 pm
Forum: International Tax
Topic: Non resident paye
Replies: 3
Views: 1958

Re: Non resident paye

The Spanish resident Director will need good advice on his Residence position. 1: Has he made the " Distinct BreaK" from the UK. No available Accomodation severed his links here. 2: Has he filed as a resident in Spain and obtained a tax number and got an Accountant/ Agent there? 3: The Company will ...
by Taxbar
Mon Jun 08, 2009 10:40 am
Forum: International Tax
Topic: UK/US tax
Replies: 7
Views: 2463

Re: UK/US tax


Is this post about you or your mother?

I can assist with the UK/US treaty but would usually work with a US Colleague on US issues as these are very complex.

I am in Manchester and most US tax advisers who can advise, will be in London.


Daniel Feingold

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