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Residence & domicile
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30
After the amnesty
JOHN CASSIDY considers what happens now that the offshore disclosure facility registration window has closed
A 'PE' problem
OWEN CLUTTON argues that the new 'permanent establishment' test for trustee residence in TCGA 1992, s 69(2D) is too onerous.
Peering through the fog
REG DAY considers the range of information that is now available to HMRC to check disclosures under the offshore disclosure facility and to target those who do not come forward.
Transfers abroad
REBECCA MURRAY looks at the new Income Tax Act 2007 provisions relating to the transfer of assets abroad.
Into the IOMosphere
JOHN NUGENT considers tax residence in the Isle of Man for UK individuals and their business interests.
Offshore but unsure?
PENNY BATES presents an idiot's guide to the taxation of settlors and beneficiaries of offshore trusts.
Stuck in the groove!
RICHARD CURTIS goes back in time to look at the domicile record
Domicile or bust?
KEVIN SLEVIN believes it is time for a fundamental rethink of the rules for non-domiciles and overseas income and gains
Is it really a bargain?
ROBERT MAAS suggests that practitioners think carefully before biting into HMRC's offshore disclosure facility.
Kind heart and coronet
MIKE TRUMAN examines the known facts in the case of Lord Laidlaw, and asks what the true residence position is.
Taxables - The next generation
RICHARD CURTIS 'sits in' on another visit to the Taxables by their chartered tax adviser.
On the buses
It is important to be sure of your ground in relation to company residence, says JIM WILSON.
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This week's opinion: 9 January 2025
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Seven million people use HMRC app
Latest agent update available