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Library page: residence status

19 June 2009
Categories: Residence & domicile
A run-down of Taxation news, comment and analysis of recent developments in residence and non-domiciled status legislation

News

Requirements not satisfied
R (on the application of Davies and another) v CRC; R (on the application of Gaines-Cooper) v CRC, Court of Appeal

Gaines-Cooper refused judicial review
Taxpayer seeks leave to appeal to Supreme Court

IR20 guidance not exhaustive, insist HMRC
Gaines-Cooper: Court of Appeal, third and final day

Residence case hears taxman's 'dichotomy'
Gaines-Cooper: Court of Appeal, day two

HMRC ‘changed policy to catch non-residents’
Gaines-Cooper: Court of Appeal, day one

Grace is returned to First-tier Tribunal
Appeal judges rule there is room for doubt

Major residence cases set for appeal court
Final decision in Grace; Gaines-Cooper to be heard

Goodbye, IR20
Replaced by HMRC6

New regime from 6 April 2009
Summary of changes to domicile and residence rules

Quarter of non-doms 'set to quit UK'
KPMG warns of potential £90m loss

Residence and domicile
HMRC Q&A confirms Statement of Practice 5/84

Extra guidance for non-doms
More FAQs re. new remittance basis rules

High Court rules for HMRC in Grace case
Special Commissioner overturned for first time in 100 years

Multinationals 'not handling non-dom rules'
Majority have no firm policies in place: study

Statutory residence test 'a possibility'
Kennedy agrees to consider idea in Finance Bill debate

AIC defends offshore tax havens
Support for 'legitimate role going offshore can play'

London hurt by tax changes: survey

Capital's execs blast non-dom rules

UK 'still best place for non-doms'
Jobs, property prices and London are all factors

Lords criticise new residence laws
Sub-committee says nation's competitiveness could suffer

CIOT backs residence test amendment
Lib Dems applauded for move to alter Finance Bill

Treasury's £35K non-dom deal 'reasonable'
Use of US law firm was practical solution, says former CIOT president

Non-dom rules 'too focused on wealthy'
Insufficient consideration of impact on other income groups, says Treasury Committee

Legal sector warns of non-dom threat
Law Society calls for extra consultation

Letdown as Darling holds steady on non-doms

Call for 'much more bravery'

Renewed attacks on non-dom reform
CIOT and CBI call for 12-month deferral

Largest non-dom group being 'forced out'
Reform 'will cause exodus' of south-Asian taxpayers

No U-turn on domicile proposals
HMRC have clarified certain points in the residence and domicile consultation

Residence reform will hit 'every non-dom'
Those with investments held in offshore trusts most vulnerable, warns PKF

Residence reform: new amendments unveiled
Latest provisions will make a series of changes to current rules

Poor 'could be hit by residence reforms'
Low-income groups face a 'bureaucratic nightmare', claims LITRG

Non-dom rules could 'kill golden goose'
'Important core of people' wil be hardest hit by changes, warns finance veteran...

Domicile consultation finally appears
But no relevant legislation - which is promised 'soon'

CIOT wants non-dom plans deferred
Body calls for CGT changes for trusts and companies set up by non-doms to be halted until properly assessed

CIOT calls for residence test
'Current law determining domicile status is a mess'

PBR 2007: the reactions
Unsurprisingly, the Government's latest Pre-Budget Report sparked a broad variety of responses from a wide range of tax professionals and political figures

Pre-Budget Report 2007
Highlights of the Chancellor's speech to the Commons

Cable: limit non-domicile status to ten years
The Liberal Democrats have called on Gordon Brown to remove non-domicile status from anyone who has been resident in the UK for a decade or more

Experts disagree over Tory tax plan
The shadow chancellor's newly announced plan for people holding non-domiciled status has divided opinion among tax professionals

Tories will charge non-domiciled £25,000
Those who enjoy non-domiciled tax status in the UK will be required under the next Conservative government to pay an annual levy of £25,000

Warning over tax returns for non-residents
PricewaterhouseCoopers has alterted those with non-domicile status that HMRC have updated their line of questioning on the latest self-assessment tax returns

Cable's tax speech draws 'caution' warning
Leading tax expert John Whiting has suggested care be taken on potential reforms, following criticism by the Liberal Democrat's Vincent Cable of perks for the 'super-rich'

Analysis

Leaving on a jet plane
CHRISTOPHER STONE explains the implications of Gaines-Cooper v HMRC for non-residence

The final blow?
PETER VAINES discusses whether we have reached the end of the road for ordinary residence

Cheque it out
2008/09 is the first time that the new remittance basis rules will be seen on a self assessment tax return. SAM HART goes back to first principles to clarify the rules

Shine a light
JAMES KESSLER considers the topic of residence in the light of the new publication, HMRC6

A pyrrhic victory
ROB GELL and PHIL DAVIS consider the cost of HMRC’s win in the Genovese case

Offshore access
MALCOLM FINNEY considers the implications of non-UK domiciles accessing offshore monies following FA 2008

Bowled by a googly
MIKE TRUMAN reports on the High Court judgment in the Grace case

Howzat?
MIKE TRUMAN and CHARLENE CHOI listened to the arguments in court as HMRC appealed the taxpayer's win in Grace

Going with the flow

TIM KEELEY urges advisers to ensure that claiming the remittance basis will be advantageous

Home is a range
The potentially confusing issue of residence in the UK is explored by JOHN CULLINANE

Alien concept
MALCOLM GUNN FTII, TEP offers help for clients pleading, 'no tax please, we're not British!'

Straight bat
At last, a BA pilot is held to be non-resident. MIKE TRUMAN explains how playing a straight bat on a sticky wicket led to victory

Good news week?
Always look on the bright side... MIKE TRUMAN searches for the silver lining in the grey and foggy cloud that was the Chancellor's 2008 Budget

Damp squib
MIKE TRUMAN offers his initial reaction to the 2008 Budget

A lot of thinking to do!
PHILLIP DEARDEN reviews the ramifications of the draft legislation on residence and domicile

Polarised opinion
If a group of disparate professionals cannot agree on residence and non-domicile tax issues, what hope is there for sensible legislation, asks ALLISON PLAGER

Eight days a week
MIKE TRUMAN gets to grips with the consultation document on residence, which proposes that a week spent in the UK will count as eight days

Domicile and residence
PHILLIP DEARDEN reviews the potential impact of the Pre-Budget Report announcements

Comment

Return journey
Grace has been sent back to the First-tier Tribunal for reconsideration. MIKE TRUMAN looks at the judgment

House of cards
Assurances on how HMRC will use their powers do not prevent individual Inspectors from taking a different view, as MIKE TRUMAN recently witnessed

Alien entanglements
Even for non-domiciliaries with quite straightforward financial affairs, the new remittance rules are monstrously complicated and opaque, warns SIMON MCKIE

Squeezing the pips
The new non-domicile tax regime has been cobbled together and will be bad for UK plc, says SIMON MCKIE

So long, farewell
MIKE TRUMAN points the way to the exit for aggrieved non-domiciles

Simply unfair
MIKE TRUMAN is not impressed by the unanimity between Conservative and Labour on the taxation of non-domiciles

Categories: Residence & domicile
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