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From garage to unicorn – Employment law lessons for scaling tech teams
Catherine Bourne
In 2007, the Conservative Party made much of a party pledge in its manifesto to increase the Nil Rate Band for inheritance tax to £1m. In July 2015, having been elected to form a majority government they announced the introduction of a Residence Nil Rate Band (RNRB). Now that more of the detail has emerged in relation to this policy announcement, the reality does not match the expectations of many and some of the details are still unclear.
In July 2015, the U.K. Supreme Court in Anson v Commissioners for HM Revenue & Customs [2015] UKSC 44 held that a UK resident’s share of the profits in a Delaware limited liability company (“LLC”) qualifies for a UK tax credit under the 2001 Income and Capital Gains Tax Convention between the UK and US (“the Convention”) because the profits that were to be taxed in the UK were the same as those taxed in the US.
Over the past few years there have been significant changes to the taxation of UK residential property. To those not significantly in the know, navigating through the changes can be complex and difficult so we have provided an outline of the changes and the rules as at September 2015. In particular, we explain those changes that affect the non-UK domiciled purchaser of UK residential property.
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