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Tolley's Tax Planning for Owner-Managed Businesses 2017-18

Tolley's Tax Planning for Owner-Managed Businesses 2017-18

  • 作者:
  • 出版商: LexisNexis U.K.
  • ISBN: 9780754553960
  • Previous Edition ISBN: 9780754552734
  • 出版时间 December 2017
  • 规格: Paperback
  • 适应领域: U.K. ? 免责申明:
    Countri(es) stated herein are used as reference only
New Edition is available now !
  • 描述 
  • 大纲 
  • 详细

    In the current climate, businesses are expecting their advisers to help them make more savings through careful tax planning than ever before. This title enables you to give real-life solutions and guidance on problems faced in every stage of the life-cycle of an owner-managed business.

    All the key issues are covered in a clear and precise manner, including the interaction of different taxes and the Finance Act 2017, to ensure there is a thorough analysis of planning opportunities in each transaction or event.

    Written by providers of advice to practitioners and their clients, this practical title uses worked examples and case studies to explain tax liabilities, compliance and planning opportunities available for tax mitigation, and, as such, is essential reading for anyone handling the affairs of owner-managed businesses.

  • Preface
    Author Biographies
    Table of statutes
    Table of statutory instruments
    Table of cases

    PART A PLANNING
    Section I: UK Resident and Domiciled Individuals: use of
    Offshore Structures as Tax Shelters
    1 Offshore trusts
    2 Offshore companies
    3 Offshore funds
    4 Life policies
    5 Overview
    6 Holding companies
    7 Traps and pitfalls
    8 Income distributions
    9 Capital distributions
    10 Planning points in relation to capital distributions
    11 Bringing the trust onshore
    12 Basic planning
    13 Pre-arrival planning
    14 Bringing money to the UK
    15 Identifying non-UK investments
    16 Mitigating tax on UK investments
    17 Home ownership
    18 Creating offshore settlements
    19 Foundations
    20 Anticipating UK domicile or deemed domicile
    21 General
    22 Provision for the settlor
    23 Provision for other beneficiaries
    24 CGT planning
    25 Sheltering business profits
    26 Employee benefit trusts
    27 Investment in real estate by offshore companies
    28 UK houses for non-residents
    29 Emigration
    30 Migration of trusts
    31 Company migration

    PART B THE DOMESTIC LEGAL FRAMEWORK
    32 Characterisation
    33 Characterisation of foundations
    34 Sham trusts
    35 Territorial limits
    36 Situs of assets: general rules
    37 CGT situs rules
    38 Source
    39 The residence of individuals
    40 Residence of trusts
    41 Residence of companies
    42 Domicile: general principles
    43 Domicile for inheritance tax
    44 Eligibility for the remittance basis
    45 Long-term residents: the annual charge for the remittance basis
    46 Relevant foreign income
    47 Foreign chargeable gains
    48 Earnings
    49 Core meaning of ‘remittance’
    50 Derivation
    51 Mixed funds
    52 Relevant persons
    53 Services provided in the UK
    54 Debts relating to property enjoyed in the UK
    55 Anti-avoidance provisions: Conditions C and D
    56 Business investment relief
    57 Other exemptions from tax on remittances
    58 The relevant property regime
    59 Exceptions to the relevant property regime
    60 Excluded property and settlements
    61 Excluded property and the relevant property regime
    62 UK income of non-residents
    63 UK gains of non-residents
    64 ATED and ATED related CGT
    65 Stamp duty land tax
    66 Relevant transfers
    67 Transferors
    68 Non-transferors
    69 The s 733 computation
    70 Non-UK domiciliaries
    71 The motive defence
    72 European defence
    73 Attribution of income to the settlor
    74 Attribution of gains to the settlor
    75 Section 87
    76 Capital payments
    77 Capital payments and non-UK domiciliaries
    78 Trustee borrowing
    79 Schedule 4C pools
    80 Trust offshore income gains
    81 Reservation of benefit rules
    82 The IHT treatment of liabilities due from individuals
    83 The IHT treatment of liabilities: trusts and reservations of benefit
    84 Pre-owned assets
    85 The general anti-abuse rule
    86 Close companies
    87 Corporate gains: section 13
    88 Transfer pricing
    89 Diverted profits tax
    90 Benefits in kind
    91 Employment income provided through third parties
    92 Offshore funds
    93 The regime applicable to life policies
    94 Introduction to DTTs
    95 Treaty residence
    96 Overview of distributive articles
    97 Availability of relief
    98 Problem entities
    99 DTTs and anti-avoidance legislation
    100 The fundamental freedoms
    101 Impact of the freedoms on anti-avoidance legislation
    102 The Liechtenstein Disclosure Facility
    103 The UK/Swiss Tax Cooperation Agreement

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