Section 965 Transition Tax
Many Americans with overseas business interests (i.e. business interests outside the USA) will face additional tax bills this year under the new transition tax rules enacted on 22 December 2017. Although these rules were intended to persuade the likes of Apple and Google to repatriate their historic profits to the US from low tax jurisdictions, they have also swept up other US citizens and green card holders who have more than a 10% interest in a controlled foreign ...
Please click here for our 2017/18 year end personal tax planning tips.
Finance (No. 2) Act 2017 introduced new Requirement to Correct (RTC) legislation which is targeted at non-complicance in respect of offshore tax matters.
Taxpayers who know or suspect that they have unpaid tax relating to overseas assets, income or activities need to act before the 30 September 2018 deadline.
Failure to take corrective action will result in much higher penalties being applied for their non-compliance. From 1 October 2018 the minimum penalty will be 100% of the tax owed, but ...
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 has ...
Russ Cahill our Corporate Tax Partner advised on the recent Feel Good Group / Perwyn private equity deal providing providing tax advice to the management team.
The Feel Good Group, is behind the well-known Tanning Shop brand one of the largest operators of it's kind in the UK.
Dow Schofield Watts Corporate Finance initiated and led the transaction. Advisers to management were: legal – The Endeavour Partnership; tax - Tax Advisory Partnership. Advisors to Perwyn and HSBC were: financial ...
We have assisted several clients with mixed fund cleansing already and now outline here how we have helped one particular client.
Our client had an offshore investment portfolio with a value of £1M. The portfolio was invested in 10 different assets.
The portfolio had been established with pre-arrival capital and was added to with UK taxed employment income, income and gains within the portfolio have been reinvested.
A remittance to the UK from this portfolio would have triggered taxes on the income and gains ...
This year’s General Election resulted in a period of uncertainty for non-UK domiciled ("non-dom") taxpayers as anticipated tax laws were dropped from the Finance Bill.
These changes have now been introduced and are effective from 6 April 2017 as originally intended.
The new legislation has a material impact on how non-doms are taxed in the UK, so certain transitional reliefs have been introduced specifically:
1.Mixed fund cleansing - allowing non-doms the opportunity to identify and remit clean capital from a ...
The press often includes articles about cryptocurrency and bitcoin's – perhaps discussing their future, fluctuating values and countless speculation on the types of individual that use the currency.
Therefore most of us by now have some level of understanding of these types of virtual currency, however these articles never mention the UK tax treatment.
Whether the treatment of income and losses made in connection with, activities involving Bitcoin and other similar cryptocurrencies will be subject to UK tax will ...
We anticipate that the Finance (No.2) Bill will be passed through to Parliament early this Autumn. Much of the Bill is concerned with anti-avoidance measures, and one potentially punitive provision is the requirement on taxpayers to correct any historic 'offshore' tax evasion and non-compliance.
The draft legislation in the Bill introduces a final deadline of 30 September 2018 for those with undisclosed tax liabilities relating to income/gains or assets outside the UK to make a report to HMRC. Thereafter, those ...
The Autumn Statement in 2016 brought about a change to the VAT Flat Rate Scheme, which has taken effect rom 1st April 2017 onwards.
Brief summary of the Flat Rate Scheme
The Flat Rate Scheme (“FRS”) is a simple and cost effective way of minimising VAT record keeping requirements. The Government introduced the scheme as an incentive to help simplify taxes.
How does it work?
If you are VAT registered, then you charge 20% VAT on your sales invoices but ...