The private client briefing for September 2013

HMRC has published guidance on the new restrictions on the deductibility of debts for IHT purposes and the new measures allowing a non-UK domiciled spouse to elect to be treated as UK domiciled for IHT purposes. HMRC has also published a consultation on promoters of ‘high-risk’ tax avoidance schemes. The High Court has ruled on two equitable principles in relation to gifts. HMRC has suspended its campaign targeting non-doms over remittance errors. The start date for the US Foreign Accounts Tax Compliance Act withholding tax regime has been postponed until 1 July 2014.