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Author: Michael McGowan
Publisher: Kluwer Law International B.V.
ISBN: 9403537442
Category : Law
Languages : en
Pages : 414
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Book Description
Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ‘tax transparent’ and if so, what that means. While of great importance, the UK tax rules for classifying entities are notoriously vague, as is the UK meaning of ‘tax transparency’. This book breaks new ground by exploring these topics comprehensively, in a world which is well aware of the problems created by entity classification mismatches. In so doing, it addresses, with emphasis on UK tax law, issues such as: the meaning of a ‘partnership’ and a ‘trust’; what is meant and is not meant by ‘tax transparency’, across a range of taxes and situations; how tax treaties have dealt with entity classification questions and related ‘transparency’ issues; how entity classification questions are impacted by EU law; and how the UK approach could be improved, policy-wise and practically, without facilitating tax avoidance. The book compares in detail the UK entity classification approach with that of the US, the Netherlands and France. Appendices consider the unusual UK capital gains tax treatment of partnerships, as well as the special transparency rules which can apply where a partnership is party to loans or derivative contracts, or owns intangible assets. Questions of entity classification and tax transparency are of fundamental importance in any mature tax system and especially in a globalised economy. This book unlocks those questions for both academics and practitioners.
Author: Michael McGowan
Publisher: Kluwer Law International B.V.
ISBN: 9403537442
Category : Law
Languages : en
Pages : 414
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Book Description
Imposing UK tax on an entity or those linked to it involves understanding what kind of entity is being dealt with, especially when it is formed outside the UK. Is it a company, a partnership, a trust or something else? This often involves considering whether the entity is ‘tax transparent’ and if so, what that means. While of great importance, the UK tax rules for classifying entities are notoriously vague, as is the UK meaning of ‘tax transparency’. This book breaks new ground by exploring these topics comprehensively, in a world which is well aware of the problems created by entity classification mismatches. In so doing, it addresses, with emphasis on UK tax law, issues such as: the meaning of a ‘partnership’ and a ‘trust’; what is meant and is not meant by ‘tax transparency’, across a range of taxes and situations; how tax treaties have dealt with entity classification questions and related ‘transparency’ issues; how entity classification questions are impacted by EU law; and how the UK approach could be improved, policy-wise and practically, without facilitating tax avoidance. The book compares in detail the UK entity classification approach with that of the US, the Netherlands and France. Appendices consider the unusual UK capital gains tax treatment of partnerships, as well as the special transparency rules which can apply where a partnership is party to loans or derivative contracts, or owns intangible assets. Questions of entity classification and tax transparency are of fundamental importance in any mature tax system and especially in a globalised economy. This book unlocks those questions for both academics and practitioners.
Author: Emma Chamberlain
Publisher:
ISBN: 9780414043350
Category : Trusts and trustees
Languages : en
Pages : 1679
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Book Description
Trust Taxation covers the taxation of UK resident and non-resident trusts explaining in detail the income tax, capital gains tax and inheritance tax treatment of the various different types of trusts. The book covers the tax consequences of creating and ending a trust, as well as the tax issues to consider during the lifetime of each type of trust and on distributions to beneficiaries. Part 1 contains an overview of trust law including recent case law on Hastings Bass, the categorisation of foreign entities, the new domicile and residence proposals and case law on residence and domicile generally. It also summaries the tax rules for foreign domiciliaries. Parts 2 to 4 explain the relevant legislation in detail as it relates to trusts, including discussion of entrepreneurs' relief, rollover relief, reservation of benefit, excluded property and relevant property trusts. Part 5 deals with special situations, including the family home, chattels, employee benefit trusts, pilot trusts, bare trusts, disabled trusts, will drafting, variations, business property relief and agricultural property relief, divorce and trusts.
Author: Guglielmo Maisto
Publisher: IBFD
ISBN: 9087220758
Category : Domicile in taxation
Languages : en
Pages : 709
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Book Description
This book deals comprehensively with the problems raised by residence of individuals for tax purposes. It begins with an overview of residence of individuals in private international law, with a particular emphasis on general principles on residence and conflict of law rules. It then examines issues raised by residence of individuals in EC (non-tax) law. Individual country surveys provide in-depth analyses from a national viewpoint. The following countries are discussed: Australia, Austria, Belgium, Canada, France, Germany, Italy, Japan, Netherlands, Spain, Switzerland and United Kingdom.
Author: Sidney I. Roberts
Publisher:
ISBN:
Category : Aliens
Languages : en
Pages : 1132
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Book Description
Author: Robert L Williams
Publisher: Bloomsbury Publishing
ISBN: 1847665098
Category : Law
Languages : en
Pages : 815
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Book Description
This unique book is a concise but complete tax planning manual for those advising high net worth individuals of the UK, US or any other nationality who have UK or US residence, assets or family members. Guide to US/UK Private Wealth Tax Planning covers all the information and legislation you are likely to require when advising clients exposed to both UK and US taxation, providing you with: A quick reference summary of the UK and US rules applicable to your clients; A comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US; Optimal income and gains tax planning for foreign trusts with UK or US beneficiaries; Integrated UK and US tax planning solutions for clients exposed to both UK and US tax. Previous edition ISBN: 9781845920272
Author: James Kessler KC
Publisher: Bloomsbury Publishing
ISBN: 1526507994
Category : Law
Languages : en
Pages : 842
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Book Description
Legal, tax and accountancy practitioners will find this accessible book truly indispensable. It supplies the tools and instructions that will help you build watertight trusts and will trusts in Northern Ireland. This superb book allows you to draft crisp, accurate legally binding trusts and will trusts with the minimum of research. Benefit from: - The practical precedents - use these to create accurate trusts and will trusts time after time; - The latest legislation - everything you need to know on Northern Ireland law and tax law; - All you need to know on trustees - the role and responsibilities, plus how to appoint somebody; - Key financial advice on stamp duty transactions; - A vast amount of knowledge and experience from two leading experts in this field. The main legislative change since the last edition published in 2013 has been the introduction of the complex residence nil rate band which will be covered comprehensively. Practitioners who have little involvement with inter vivos trusts will find this book invaluable for the will drafting chapters. Another important legislative change since the publication of the last edition is the Charities Act (NI) 2013 which clarified the public benefit test and which is also covered in detail in this new edition.
Author: Peter Harris
Publisher: Cambridge University Press
ISBN: 9780521853118
Category : Law
Languages : en
Pages : 520
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Book Description
Inspired by a postgraduate course the authors have jointly taught at the University of Cambridge since 2001, Peter Harris and David Oliver use their divergent backgrounds (academia and tax practice) to build a conceptual framework that not only makes the tax treatment of complex commercial transactions understandable and accessible, but also challenges the current orthodoxy of international tax norms. Designed specifically for postgraduate students and junior practitioners, it challenges the reader to think about tax issues conceptually and holistically, while illustrating the structure with practical examples. Senior tax practitioners and academics will also find it useful as a means of refreshing their understanding of the basics and the conceptual framework will challenge them to think more deeply about tax issues.
Author: United States. Tax Court
Publisher:
ISBN:
Category : Law reports, digests, etc
Languages : en
Pages : 1160
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Book Description
Final issue of each volume includes table of cases reported in the volume.
Author: United States. Tax Court
Publisher:
ISBN:
Category : Taxation
Languages : en
Pages : 1158
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Book Description
Author: District of Columbia
Publisher:
ISBN:
Category : Law
Languages : en
Pages : 952
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Book Description
