Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent developments.
This article reviews key developments in private client tax which occurred in recent weeks.
Grandfathering of concessionary treatment for pre-4 August 2014 loan collateral
HMRC published a briefing note on 15 October 2015 updating its plan to withdraw concessionary treatment for foreign income and gains used as security for commercial loans brought to or used in the UK by remittance basis users. The withdrawal was originally announced on 4 August 2014 with a limited transitional period for reorganising pre-4 August 2014 loans. Such loans needed to be reorganised prior to 5 April 2016 and a written undertaking given to HMRC no later than 31 December 2015 that the loan...
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Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent developments.
This article reviews key developments in private client tax which occurred in recent weeks.
Grandfathering of concessionary treatment for pre-4 August 2014 loan collateral
HMRC published a briefing note on 15 October 2015 updating its plan to withdraw concessionary treatment for foreign income and gains used as security for commercial loans brought to or used in the UK by remittance basis users. The withdrawal was originally announced on 4 August 2014 with a limited transitional period for reorganising pre-4 August 2014 loans. Such loans needed to be reorganised prior to 5 April 2016 and a written undertaking given to HMRC no later than 31 December 2015 that the loan...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
