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Where Taxpayers and Advisers Meet

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by Brightonian
Wed Nov 28, 2018 3:10 pm
Forum: International Tax
Topic: US withholding tax on dividends
Replies: 3
Views: 608

US withholding tax on dividends

I am puzzled and wonder if anyone can enlighten me. My client received dividends from the US parent of a company of which he is a director. 25% tax has been withheld. He has a tax liability in the UK, as the dividends exceed the dividend allowance. He is an additional rate taxpayer so his UK liabili...
by Brightonian
Thu Oct 04, 2018 11:33 am
Forum: International Tax
Topic: Double taxation agreement - article 15
Replies: 3
Views: 682

Re: Double taxation agreement - article 15

Thank you, Maths. I thought that might be the case but wasn't sure. Also there were UK liabilities on the rental of his UK home in 2014/15 and 2015/16 and I do not believe that the Italian accountant claimed a credit for the UK tax against the Italian tax. So all a bit messy really. Once again, than...
by Brightonian
Thu Oct 04, 2018 6:32 am
Forum: Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
Topic: R185 for life tenant
Replies: 2
Views: 593

Re: R185 for life tenant

Τη

Thank you, Maths. That is very clear indeed and I am very much obliged to you.
by Brightonian
Wed Oct 03, 2018 1:53 pm
Forum: International Tax
Topic: Double taxation agreement - article 15
Replies: 3
Views: 682

Re: Double taxation agreement - article 15

I have a little more research and tried to get my head round this. Under the treaty, he will be UK resident, as he is a UK national, so it just depends on how we interpret Article 15. He would only be taxable in the UK except where the employment is carried out in Italy. it was carried out in Italy ...
by Brightonian
Wed Oct 03, 2018 12:00 pm
Forum: International Tax
Topic: DTA interpretation - practical aspects
Replies: 2
Views: 1027

Re: DTA interpretation - practical aspects

For complicated reasons, this case was put down and only recently picked up again. I have looked at Article 15. Under their domestic law, he is resident in both countries but do I assume for the purposes of the article that he is UK resident (because that is the answer after the tie break questions)...
by Brightonian
Tue Oct 02, 2018 5:19 pm
Forum: International Tax
Topic: Double taxation agreement - article 15
Replies: 3
Views: 682

Double taxation agreement - article 15

My client lived and worked in Italy for two years. Last year, he spent more time in the UK and will be judged UK resident under UK law for 2017/8. He will also be Italian resident under Italian domestic law for 2017 and possibly 2018 also,although that is not so clear cut. I am completing his 2017/1...
by Brightonian
Tue Oct 02, 2018 2:05 pm
Forum: Inheritance Tax, IHT, Trusts & Estates, Capital Taxes
Topic: R185 for life tenant
Replies: 2
Views: 593

R185 for life tenant

I have recently taken over an IIP trust, which was previously managed by a trust company. I have all the information needed to prepare the 2017/18 trust tax return. In addition, the life tenant's accountants will need an R185. I have never prepared an R185 for an IIP - just for discretionary trusts....
by Brightonian
Fri Jun 15, 2018 3:02 pm
Forum: International Tax
Topic: DTA interpretation - practical aspects
Replies: 2
Views: 1027

DTA interpretation - practical aspects

I have no experience of claiming relief under DTAs. I have a client, a dual UK/S African national, who went to work in Italy in 2014. I have completed returns for the last few years to show rental income on their UK property. I have shown him as non-resident by virtue of automatic overseas test 3, w...
by Brightonian
Tue Jun 12, 2018 9:47 am
Forum: Income Tax
Topic: Trading Income Allowance and non-exec director
Replies: 4
Views: 631

Re: Trading Income Allowance and non-exec director

Robbob,
Thank you very much for your comprehensive reply. Every year we seem to have some new provision or allowance which looks simple on the face of it but throws up miscellaneous problems in practice!
by Brightonian
Tue Jun 12, 2018 9:15 am
Forum: Income Tax
Topic: Trading Income Allowance and non-exec director
Replies: 4
Views: 631

Re: Trading Income Allowance and non-exec director

Thank you for taking the time to respond. On your final point, however, it seems from the tax return notes that 'miscellaneous income from casual earnings, commission or freelance income' can be covered by the trading income allowance.

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