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Residence & domicile

JOHN CASSIDY considers what happens now that the offshore disclosure facility registration window has closed
OWEN CLUTTON argues that the new 'permanent establishment' test for trustee residence in TCGA 1992, s 69(2D) is too onerous.
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.
REBECCA MURRAY looks at the new Income Tax Act 2007 provisions relating to the transfer of assets abroad.
JOHN NUGENT considers tax residence in the Isle of Man for UK individuals and their business interests.
PENNY BATES presents an idiot's guide to the taxation of settlors and beneficiaries of offshore trusts.
RICHARD CURTIS goes back in time to look at the domicile record
KEVIN SLEVIN believes it is time for a fundamental rethink of the rules for non-domiciles and overseas income and gains
ROBERT MAAS suggests that practitioners think carefully before biting into HMRC's offshore disclosure facility.
MIKE TRUMAN examines the known facts in the case of Lord Laidlaw, and asks what the true residence position is.
RICHARD CURTIS 'sits in' on another visit to the Taxables by their chartered tax adviser.
It is important to be sure of your ground in relation to company residence, says JIM WILSON.
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