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Private client briefing for January 2017

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An AG opinion confirms that there is an indirect incompatibility between TCGA 1992 s 80 and EU law. There are tribunal decisions on the nature of foreign currency and the implications of this for CGT purposes; and on the factors to be taken into account when assessing a CGT main residence election. The High Court rules on the application of the rectification test to a defective IHT double-trust arrangement. The government has published details of new tax changes affecting non-doms in the long-awaited draft Finance Bill 2017.

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