Residence & domicile

PHILIP FISHER raises the alarm for individuals who are seconded overseas but also need to work in the UK

Dr A H Tuczka v CRC, Upper Tribunal (Tax and Chancery Chamber)

A non-dom has set up an offshore trust of which one of the beneficiaries is resident in the UK. Questions include the gift of income from one beneficiary to another and the implications of dividends from a subsidiary company

The Taxation team responds to George Osborne's announcements

Gudiance for Egypt, Tunisia, Bahrain and Libya evacuees

Hansard, 13 January 2011, vol 521, no 98, col 556W

Lyle Grace (TC913)

A US citizen who has lived in the UK for two years is the beneficiary of a US grantor trust and a US non-grantor trust

Legal experts blame annual remittance-basis charge

Removal of warnings of no legal force

Advice is required on whether the £2,000 threshold for the remittance basis for non-domiciles can apply without a formal election

A company is resident in both the UK and in Brazil and wonders whether loss relief will be available as group relief in the UK and by carry forward in Brazil. It seems to be that loss relief can be given in both countries but the operation of double taxation relief will mean that relief is only effectively given once