8 Nov 2023
The Taxman Cometh – Soon – Andrew Parkes
We have mentioned previously (see our January 2022 Newsletter) that the UK will seek to tax any income from a trade carried on in the UK by a non-resident, but that this is blunted where there is a Double Taxation Agreement (DTA) between the UK and the country of residence of the trader. Where there […]
8 Nov 2023
The Paradox of Tax Planning and Morality: A review of Taxpayer v HMRC – Chimezirim Echendu
Introduction In Finance Act 2013, the UK introduced a statutory residence test (SRT) to provide an objective way of determining the residence of individuals. The test, although based substantially on day counting and days spent in the UK, also relies on the substance and quality of an individual’s residence to determine tax residence. As days […]
8 Nov 2023
But why? – Not the cry of every toddler, but why a relief is due – Andrew Parkes
One of the real joys (and I’m not being sarcastic here) of working in International Tax is that what seems to be the simplest of questions can have the most hidden of answers. The UK’s distribution exemption (i.e. dividends received from underlying subsidiaries are exempt from UK taxation) for small companies is only available where […]
24 Oct 2023
US Taxpayers Saving for Retirement – Mike Haynes
Head of Employment and Pensions Mike Haynes discusses how US taxpayers can save for retirement in the UK while avoiding common associated problems.
20 Oct 2023
The standards are coming! The standards are coming! – Zoe Wyatt and Dion Seymour
Zoe Wyatt and Dion Seymour, discuss the global implications of new US crypto tax reporting rules, in Bloomberg Tax.
29 Sep 2023
Letter to the Editor: There is no moral justification to tax an individual upon their death
Miles Dean, Head of International Tax, explains why inheritance tax should be “scrapped altogether”, in The Guardian.
18 Sep 2023
Ready Player One: what financial services professionals need to know about web 3 and the metaverse
Crypto Tax & Accounting Technical Director, Dion Seymour, discusses the development of web3 technologies and their potential impact on financial services professionals, in Thomson Reuters Regulatory Intelligence.
18 Sep 2023
US Tax on ISAs – Paul Lloyds and Keith Meyer
Private Client Partners Paul Lloyds and Keith Meyer discuss the US tax perspective on ISAs and the difficulties US citizens face when utilising them.
1 Sep 2023
The UK tax regime for non-dom fund managers – Julian Nelberg and Mike Haynes
Head of Private Clients Julian Nelberg and Head of Employment and Pensions Mike Haynes discuss the UK tax regime for non-domiciled fund managers and how this changed following anti-avoidance legislation in 2015.
16 Aug 2023
Important tax issues when relocating to the UK – Julian Nelberg, Paul Lloyds, and Keith Meyer
Private Client Partners Julian Nelberg, Paul Lloyds, Mike Haynes and Keith Meyer discuss important tax issues to consider for those relocating to the UK, such as whether non-domiciled status applies to them and how their assets and investments should be structured.
15 Aug 2023
Crypto Is a New Type of Personal Property, UK Commission Finds – Dion Seymour
Crypto Tax & Accounting Technical Director, Dion Seymour, discusses the Law Commission’s final report on digital assets, the four recommendations made in the report, and how property rights and taxation apply to crypto under English law, in Bloomberg Tax.
10 Aug 2023
Cryptoassets: widespread misunderstanding on tax treatment must be addressed – Dion Seymour
Dion Seymour discusses the need for broader understanding among cryptoasset owners of the tax implications of these assets, in Thomson Reuters Regulatory Intelligence.