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Keeping the peace at Christmas – top tips for shared parenting over the festive season
Lauren Evans
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 our blog Neither a borrower (with foreign income or gains used as collateral) nor a lender be… published on 3 September 2014, we reported on HMRC’s withdrawal of its concession with respect to foreign income and gains used as security for loans used in the UK by UK resident non-UK domiciled individuals (‘non-doms’) claiming the remittance basis. Consequently, using foreign income or gains as security for a loan used in the UK is treated as a taxable remittance. Following discussions with representative bodies, HMRC has announced that it will not apply this change to arrangements where the loan was brought into or used in the UK before 4 August 2014.
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.
Lauren Evans
Roberta Draper
Christopher Perrin
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