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UK Tax Position on US LLCs

Historically there has been a total mismatch between the UK and the USA on the tax treatment of US LLCs.   In the USA tax transparent with members being taxed on profits arising and so being required to register under the USA tax system In the UK taxed as a company with members being taxed on profits withdrawn as if dividends but with no...

Date: 1st July, 2015   |   Author: Cathy Corns   |   Comments: 0


Summer Budget 2015 predictions

Whilst we know the Summer Budget 2015 will include provisions to prevent any rise in the rates of income tax or VAT until 2020, there is no such promise for any other taxes.  Changes could well be announced for CGT, IHT, corporation tax, SDLT or ATED.  We may also see generous reliefs reduced.  Either way, to help tackle the budget...

Date: 16th June, 2015   |   Author: Helen Price   |   Comments: 0


Commercial Property and Pensions

The tax efficiencies offered through pension schemes make the option to hold business premises within them far more attractive than often thought. Over the years pension schemes have received their fair share of criticism. The reasons for this are varied but often come down to one or a combination of the following – (1) a feeling that at...

Date: 12th May, 2015   |   Author: Michael Lapham   |   Comments: 0


Holiday Homes in Europe

Good news for the villa in the South of France! For clients owning property in Continental Europe, there has always been the problem of what happens to the property on the owner’s death, which can be further compounded by tax issues. Most European countries such as France, Spain and Italy operate ‘forced heirship’ rules so that...

Date: 7th May, 2015   |   Author: Lisa Spearman   |   Comments: 0


International Aspects

High value property in prime parts of London has long been a desirable asset of the wealthy non UK domiciled individual, whether that person is resident in the UK or not. Most individuals want to know from the outset how best they should own their UK property whether that is a residential property for their personal use or an investment property....

Date: 7th May, 2015   |   Author: Liz Cuthbertson   |   Comments: 0


Mercer & Hole’s comment: Now What for Non Doms?

Yesterday’s speech by Ed Miliband has certainly ruffled some feathers and produced a high level of media coverage. The media tends to oversimplify matters and it is not so easy to be regarded as non UK domiciled as they may portray. HMRC is more rigorous in determining whether an individual has become UK domiciled than they have been in the...

Date: 9th April, 2015   |   Author: Lisa Spearman   |   Comments: 0


Moving on to digital tax accounts

A radical step in the modernisation of the UK tax system is the announcement that digital tax accounts will be introduced with the intention that these will displace tax return filing obligations.  HMRC plan to make the new digitalised portal initially available to five million small businesses and ten million individuals by early 2016,...

Date: 19th March, 2015   |   Author: Modeten   |   Comments: 0


Annuity unlocking

There will be changes to annuities with a view to equalising the position with regards to the pension freedoms already made to income drawdown arrangements. From April 2016, individuals who have already purchased an annuity will be permitted to assign their annuity income to a third party in exchange for either a lump sum or an alternative...

Date: 19th March, 2015   |   Author: Anne McClean   |   Comments: 0


Where there’s a Will – there’s a way to change it

The use of a deed of variation (sometimes called a deed of family arrangement) is a long established practice which enables the terms of a Will to be altered by the beneficiaries after the death of the testator. If the appropriate election is made then currently the inheritance tax treatment of the will takes the variation into account. This means...

Date: 19th March, 2015   |   Author: Lisa Spearman   |   Comments: 0


The scope of Capital Gains Tax widens

1. CGT for non UK residents Non UK residents have, in general, been outside the scope of UK CGT.  With effect from 6 April 2015, non UK residents will be subject to CGT on the disposal of UK residential property.  Non UK residents include individuals, trustees and non resident companies and funds unless these are already caught by...

Date: 19th March, 2015   |   Author: Liz Cuthbertson   |   Comments: 0


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