Blog

Dual In The Crown: Considering UK and Swiss Dual Resident Status

Our Private Client Tax Partner Jamie Favell was recently featured in the ePrivate Client annual feature on Switzerland discussing the tax implications of being dual resident in the UK and Switzerland. The full content of his article can be viewed here.  [click here to go to the PDF]   For ease we have also copied the full text into this article as follows: Many high net worth individuals have mobile lives which require their advisors to consider the implications of them spending significant time in more than ... Read More

Mixed Fund Cleansing: Action Required

  To recap, if you are a non-dom living in the UK, certain tax residency milestones can impact your tax status. A £30,000 charge applies to access the remittance basis for those who have been resident in the UK for some part of at least 7 out of the previous 9 tax years.  This ‘remittance basis charge’ increases to £60,000 for individuals who have been UK resident in at least 12 of the previous 14 tax years. Since 6 April 2017, a non-dom who ... Read More

HMRC publishes guidance on cryptoasset investments

HMRC has recently published guidance for UK resident individuals on the potential liability to UK taxes that may arise on receipt or disposal of cryptoassets. The guidance is mainly concerned with cryptoassets held as investments. It is expected that HMRC will publish separate guidance for those trading cryptoassets and for companies but traders can expect to be chargeable to income tax or corporation tax (if a UK taxable company) on profits. Other taxes may apply if an individual receives cryptoassets as ... Read More

HMRC’s Crypto Guidance – New guidance for individuals to be published soon

  THIS ARTICLE HAS BEEN UPDATED ON 21/12/18 - PLEASE FOLLOW THIS LINK   TAP’s governing body the Chartered Institute of Taxation recently attended a meeting of HMRC’s crypto assets roundtable to continue the discussions around the tax treatment of crypto assets. Matters discussed included the current state of the crypto asset market, the Crypto asset Taskforce Report and the new guidance HMRC is preparing. It was confirmed that guidance aimed at individuals will be published shortly, with guidance for businesses following in early 2019. We ... Read More

Update on Tier 1 (Investor) visa program

On Friday 7 December 2018 the UK Government suspended the UK Tier 1 (investor) Visa regime at very short notice. These visas allow the right to live in the UK in exchange for investing at least £2m into the UK for a period of 5 years, after which the individual may be eligible for indefinite leave to remain in the UK. The visas have been popular with wealthy individuals from outside the EU and have brought significant funds into the UK ... Read More

UK Investor visa regime suddenly suspended

This article has been superseded by a government U-turn, follow this link for further information.     The UK’s Tier 1 (Investor) Visa scheme which allows foreign investors to live in the UK is to be suddenly suspended from midnight on Friday 7 December 2018, with the UK Government saying they have concerns that the Visa route has been used for money laundering. Tier 1 (Investor) Visas were introduced in 2008 with some reforms made in 2014. Broadly, they require the holder to invest a ... Read More

House of Lords criticises HMRC powers

Yesterday, the House of Lords’ Economic Affairs Committee has published a highly critical report on HMRC powers, describing some as “broad, disproportionate powers without effective taxpayer safeguards”. The report concludes that whilst the Committee is fully supportive of the aim to prevent deliberate evasion and aggressive tax avoidance, some recent powers given to HMRC within legislation “undermine the rule of law” and hinder taxpayers’ access to justice. In recent years HMRC have been given a number of new powers by Government to ... Read More

Probate fee increase dubbed a stealth death tax by the House of Lords

  The UK Government recently published law which, from April 2019, will increase probate fees from £155 to £6,000 for estates valued over £2 million. A Statutory Instrument is a legal mechanism with allows the Government to change a law without that change being fully scrutinised in Parliament. The House of Lords’ Legislation Scrutiny Committee has described this change as a “stealth tax” and an “abuse of power” by the Government. The fees have also been described as a de facto additional inheritance ... Read More

HMRC confirms no trust protection for offshore income gains

In April 2017 significant changes were made to the way in which UK resident but non-UK domiciled individuals (“non-doms”) are taxed in the UK. Broadly, non doms who have been resident in the UK for 15 of the previous 20 tax years are now taxable in the UK on their worldwide income and gains, as well and to inheritance tax on their worldwide assets. The changes to the income tax and capital gains tax rules would, without specific legislation in place, ... Read More

When a US/UK child is born…

Unless you have been living on Mars you will have heard that Prince Harry and Meghan Markle are expecting their first child! Whilst this may be of minor interest to the non-royalists out there, for those interested in US tax (surely a larger target audience) there will be US tax consequences for the future lord/Prince or lady/Princess. Meghan, as a US citizen and as someone who would have been residing in the US during the 5 year period prior to her child ‘s ... Read More
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