Blog
The FCA’s Enforcement Watch 2 and what it means for the financial services industry
James Alleyne
29 January 2016
International investors - five tax tales for 2016
One of the themes of recent Governments has been a tightening of the rules for the taxation of individuals with international interests. We are likely to see this theme continue in 2016. In this blog, we set out five of the key developments on this topic.
14 January 2016
Protecting a same-sex survivor’s right to pension funds
Over the past decade, the UK government has legalised same-sex civil partnerships and most recently same-sex marriages. Legislation provides that same-sex couples who are married or in civil partnerships shall be treated the same as married heterosexual couples. For example, they are entitled to receive the same inheritance tax benefits, such as the spousal exemption, which exists between a married heterosexual couple.
7 January 2016
£1m Nil Rate Band – fact or fiction?
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.
30 October 2015
HMRC offers loan collateral amnesty for non-doms
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.
2 October 2015
Legal update: HMRC’s response to the UK tax treatment of US LLCs after the Supreme Court decision in Anson
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.