Practitioner views on the Autumn Statement:
The government has published its long-awaited final proposals for CGT on non-UK residents owning UK residential property.
Andrew Goldstone (Mishcon de Reya) examines the government’s long awaited final proposals for CGT on non-UK residents owning UK residential property.
Recent media reports about the London mayor’s tax affairs shine a light on the taxation of US citizens living abroad. David Treitel (American Tax Returns Ltd) explains.
Peter Halford (PwC Legal) reviews the decision in Trigg v HMRC, where the FTT held that euro redenomination clauses did not deprive bonds of QCB status.
Mark Middleditch (Allen & Overy) provides an update of recent developments, including: the announcement of new rules on hybrid mismatches; the high-risk promoters regulations; euro conversion clauses; FATCA; and the EC investigation into the Irish tax rulings over Apple
Andrew Goldstone and Stuart Crippin (Mishcon de Reya) give an update on recent developments, including: Spanish inheritance tax refunds, pensions changes, and the cases of Hirst and Drown and another (as executors of Leadley deceased).
Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case
Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts