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Domicile and Long-Term Residence: an early domicile conclusion can become an unwanted gift

The FTT decided it had authority to determine the taxpayer’s domicile status during an application for a closure notice and appeal against an information notice
18 June 2020

Fisher v HMRC: The Upper-Tier Tribunal decision

The Upper-Tier Tribunal decision in Fisher v HMRC has clarified the scope of the Transfer of Assets Abroad code and the applicability of the motive defence
16 April 2020

Is HMRC's new draft Charter an improvement?

HMRC’s new draft Charter has some encouraging additions but a few concerning omissions will hopefully be amended before it is finalised
09 April 2020

The interactions of non-domiciled status and British citizenship by naturalisation

Is the intention to make the UK the principal home for naturalisation purposes consistent with the non-domiciled status?
10 December 2019

The Office of Tax Simplification publish second report on simplifying inheritance tax

The OTS has suggested significant inheritance tax reforms, focusing on interactions of IHT with CGT, Agricultural Property Relief and Business Property Relief, and Lifetime gifts
08 July 2019

Mixed funds and cleansing: non-doms must act soon to avoid missed opportunity

Combining the mixed fund rules and the cleansing rules presents opportunities, but non-doms must act now as the chance to 'cleanse' mixed funds is only available until 5 April 2019.

23 November 2018

Last Chance Saloon: the new "Requirement to Correct" offshore tax matters

If your affairs involve income or assets outside the UK and your UK tax filings up to 5 April 2017 for these offshore matters are not perfect, from 30 September 2018 you face stringent new penalties.
06 September 2018

Requirement to Correct: last chance saloon if you have a US account

HMRC is writing to UK residents who have accounts in the US. If you have received income or gains on a US account you should, in most cases, have declared these on your UK tax returns.
07 August 2018

ATED valuation dates: what you need to know

Companies subject to the Annual Tax on Enveloped Dwellings (ATED) will need to review before April 2018 whether the new 1 April 2017 ATED valuation date will place them into a different ATED band.
19 October 2017

Oco Limited and others v HMRC: lessons for trustees exercising discretionary powers

This recent judgment provides guidance as to what a trustee must consider when exercising a discretionary power of appointment and commentary on the distinction between bare and discretionary trusts.
06 September 2017

2017 non-dom changes confirmed: how can trustees and individuals prepare?

The changes to the taxation of non-doms and non-UK trusts are going ahead and will be backdated to take effect from 6 April 2017. We look at what trustees and individuals can do to prepare.
14 August 2017

Principal Private Residence Relief: how does PPR apply between exchange and completion?

The First Tier Tribunal has rejected HMRC’s argument that the taxpayer’s period of ownership of a property should include time taken between exchange and completion.
03 May 2017
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