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A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Jane Johnson (Birketts) advises on the IHT consequences of a US trust for US citizens moving to the UK.
Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.
Constantine Christofi (RPC) examines the legal and practical issues. 
Sarah Squires (Old Square Tax Chambers) considers how the rebasing rules apply to a recent non-resident's plans to sell UK buy-to-let properties.
Colin Hailey (Confluence Tax) outlines two options. 
Helen Mackey and Jannine Nicholas (Eversheds Sutherland) consider the application of the new tax to a UK manufacturer of food packaging.
Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.
There are a wide range of tax considerations for a UK resident limited partner, writes Katherine Bullock (Field Court Tax Chambers).