Andrew Goldstone (Mishcon de Reya) examines the government’s long awaited final proposals for CGT on non-UK residents owning UK residential property.
Recent media reports about the London mayor’s tax affairs shine a light on the taxation of US citizens living abroad. David Treitel (American Tax Returns Ltd) explains.
Peter Halford (PwC Legal) reviews the decision in Trigg v HMRC, where the FTT held that euro redenomination clauses did not deprive bonds of QCB status.
Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
Andrew Goldstone and Stuart Crippin (Mishcon de Reya) give an update on recent developments, including: Spanish inheritance tax refunds, pensions changes, and the cases of Hirst and Drown and another (as executors of Leadley deceased).
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case
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
Andrew Goldstone and Victoria Howarth provide an update, including: the increased transparency of ownership of UK companies; new HMRC guidance on the taxation of damages; a recent decision on reasonable excuse for late returns; and why professionals acting as charity trustees need to be aware of potential conflicts of interest
Peter Vaines considers the decision in Roelich on the meaning of ‘business’ for CGT incorporation relief purposes
Andrew Goldstone and Victoria Howarth review recent developments, including changes to intestacy rules, relevant HMRC consultations, the Cooke case and recently signed tax information exchange agreements