RESIDENCE

Oliver Marre

The Upper Tribunal’s decision in McCabe shows how difficult it can be to challenge findings of fact when confronted with multi-factorial tests, writes Oliver Marre (5 Stone Buildings).

Lynnette Bober

Helen McGhee

Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) examine what we know now following this week’s policy paper.

Kyle Rainsford

In GE Financial Investments, the Upper Tribunal favoured the functional interpretation while the Court of Appeal favoured the territorial, writes Kyle Rainsford (Addleshaw Goddard).

Claire Weeks

Aoife McCauley

The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).

Helen McGhee

Helen McGhee (Joseph Hage Aaronson) considers how practitioners should be advising clients during this uncertain time.

Irfan Butt

Andrew Seidler

Irfan Butt and Andrew Seidler (RSM) consider the implications for funds and real estate structures.

Dominic Lawrance

Catrin Harrison

Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.

Josh Critchlow Jill Gatehouse Alison Dickie

Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.

Nigel Giles

Michael Flaherty

Michael Flaherty and Nigel Giles (BDO) provide a refresher guide to these intricate and wide-ranging rules which can easily be overlooked when advising on migration tax planning for individuals.

Damiano Sogaro

Gideon Sanitt

Damiano Sogaro and Gideon Sanitt (Macfarlanes) review recent litigation on the tribunal's role in determining domicile issues when considering challenges to an enquiry or to information notices.