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Card image Catrin Harrison, Dominic Lawrance, Hugh Gunson
Catrin Harrison, Dominic Lawrance and Hugh Gunson (Charles Russell Speechlys) examine an Upper Tribunal decision that is disappointing for taxpayers and removes a strategic weapon for anyone faced with a domicile enquiry.
Emma Chamberlain OBE (Pump Court Tax Chambers) examines some important amendments to the excluded property provisions governing settlements.
In Henkes, the tribunal decided it can decide a taxpayer’s domicile status when determining an application for the closure of a domicile enquiry, as Nick Clayton and Dawen Gao (Herbert Smith Freehills) explain. 
The tribunal decides it has jurisdiction to determine domicile in closure notice applications. 

In this quarterly review, Adam Craggs and Michelle Sloane (RPC) consider HMRC’s increasing propensity to seek the production of documents from accountants and other professional advisers, HMRC’s new policy of challenging taxpayers’ loan relationships, and the increase in the number of domicile enquiries launched by HMRC. 

Emma-Jane Weider and Claire Weeks (Maurice Turnor Gardner) focus on those UK resident individuals who are non-UK domiciled but who will become ‘deemed domiciled’ for tax purposes from the start of the 2019/20.

Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest  tax developments that matter affecting private clients.

Arabella Murphy and Claire Roberts (Maurice Turnor Gardner) answer questions on the recent government consultation, looking at what is proposed, including the reform to non-UK resident trusts.

What can we expect in the forthcoming condoc on non-doms?

Whilst there will be no repeal of the non-dom rules, we can expect further tinkering, writes Mark Davies (Mark Davies & Associates).