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Tax Planning for Domiciled and Non-Domiciled Individuals 2013/2014

Tax Planning for Domiciled and Non-Domiciled Individuals 2013/2014
2nd Edition
Series:  S&M's Practitioner Tax Library
ISBN:  9780414028524
Published by:  Sweet & Maxwell
Publication Date:  24 Oct 2013
Subscription Information:  Non-Subscribable Product
Format:  Paperback
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Tax Planning for Domiciled and Non-Domiciled Individuals is primarily for practitioners who are involved in providing advice to individuals, trustees and executors concerning the three main taxes, namely income tax, capital gains tax and inheritance tax. Its focus is both the UK domiciled and non-UK domiciled resident individual although the UK tax issues affecting non-residents are also addressed.

Numerous examples designed to illustrate the principles and points under discussion appear throughout the text and extensive cross-referencing allows the same topic to be tracked where it is discussed in a different context.

Trusts, be they UK resident or offshore, continue to be critical to many aspects of tax planning and their use and abuse form the central core of several chapters in the book.

The legal and tax issues underpinning the various types of property ownership are discussed and their application to main residence and furnished holiday lettings examined in detail including the extensive new provisions introduced in Finance Act 2013.

For the non-UK domiciled individual whether to claim remittance basis treatment; what constitutes a taxable remittance; and whether the newly introduced business investment relief is tax efficient are all areas of interest and discussed at length.

The role of wills in inheritance tax planning (and in general) cannot be overlooked and, in particular, Deeds of Variation and other post-death adjustments are discussed in detail.

Many more topics, including international matters and SDLT, are also covered in the book.

The text is current as at the date of the Royal Assent of Finance Act 2013.


Part I – Basic Issues

  • Tax systems and their bases of taxation: an overview
  • UK Taxation: an overview
  • Domicile
  • Residence and ordinary residence for the individual
  • Residence, ordinary residence and domicile: practice
  • Income source and asset situs
  • The principles and implications of property ownership: joint tenancy and tenancy in common

Part II – Capital Taxes

  • Capitan gains tax
  • Capital losses
  • Inheritance tax: the basics
  • Inheritance tax: exemptions and reliefs
  • Inheritance tax: gifts with reservation
  • Inheritance tax: excluded property
  • Inheritance tax administration

Part III – Trusts

  • Trusts: an overview
  • Inheritance tax: trusts
  • UK resident trusts: income and capital gains taxation
  • Non-UK resident trusts: income and capital gains taxation

Part IV – Investments, main residence and furnished holiday lettings

  • Investments
  • Main residence and furnished holiday lettings
  • Non-UK domiciliaries and UK homes
  • Stamp duty and stamp duty land tax

Part V – The international dimension

  • Non-UK resident taxation
  • The non-UK domiciled individual, foreign source income and foreign capital gains
  • The offshore dimension
  • International taxation

Part VI – Wills, probate and post-death issues

  • Wills and probate
  • Wills and taxation


Malcolm Finney BSc MSc (Bus Admin) MSc (Org Psy) MCMI C Maths MIMA

Malcolm runs his own tax training firm, Pythagoras Training.
Malcolm was formerly an international tax consultant with the international finance and tax consultancy JF Chown & Co Ltd (now Chown Dewhurst LLP); partner and head of international tax at the international accountancy firm Grant Thornton LLP; and head of tax at the London-based law firm Nabarro Nathanson (now Nabarro).
Malcolm has written extensively on tax matters, has spoken at tax seminars both in the UK and abroad and has been a visiting lecturer at the University of Greenwich Business School.

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