RESIDENCE-STATUS

Andrew Goldstone and Katya Vagner (Mishcon de Reya) provide the monthly update on the latest tax developments affecting private clients.

Jonathan Cooklin

Dominic Foulkes

With the UK’s continuing attractiveness as a holding company tax jurisdiction, Jonathan Cooklin and Dominic Foulkes (Davis Polk) consider the scope of technical UK tax issues that have a direct bearing on the drafting of merger agreements and related documents which implement these transactions.

Joseph Goldman

Anthony Whall

The US Treasury recently issued new regulations to deter corporate ‘inversions’, where a US parented company and a non-US company combine and locate the tax residence of the merged company in a non-US jurisdiction. Joseph Goldman and Anthony Whall (Jones Day) review their impact.

Andre Anthony

Andre Anthony (CMS Cameron McKenna) explains the tax issues arising on the importation of a private jet into the EU by a non-EU resident.

Andrew Goldstone

Victoria Howarth

Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts

Priya Dutta

Priya Dutta answers a query on the tax residency of employees seconded to overseas offices and undertaking training in the UK

Jane Scott

Carolyn Steppler

Carolyn Steppler and Jane Scott consider whether it may be easier for some individuals to become non-UK resident under the SRT, now the concept of a ‘clean break’ has been removed

Stephen Smith sets out the practical lessons from the Paul Daniel case concerning a taxpayer who realised a substantial capital gain whilst purporting to be working full-time abroad

Priya Dutta

By Priya Dutta