Review of Tax Affairs
On receipt by our client of a generalised letter of enquiry from HMRC (of a type often described by HMRC as a ‘nudge letter’) we undertook a comprehensive review of the tax affairs of a UK resident, non-domiciled individual identifying unusual income receipts and capital gains, determining their tax treatment, advising on their disclosure to HMRC and representing the client in discussions concerning the imposition of penalties. The matter was concluded without HMRC imposing any penalties.
Capital Gains Tax on the disposal of a main residence
We advised a client on the availability of main residence relief on the disposal of his home. This involved a detailed analysis of statute and case law and their application to an unusual factual background and some very confused trust documentation, advice on the disclosure to HMRC and agreeing the tax treatment with HMRC.
Business investment relief
We advised a non-domiciled couple on the availability of business investment relief on an investment in a UK company and making a clearance application to HMRC.
We advised members of a wealthy Indian family on their domicile status. This included making a multi-factorial enquiry into their personal history and the making of full disclosure to HMRC.
Moving to the UK
The members of an ultra high net worth family engaged our advice on their proposed move to the UK. This involved advising on the action to be taken prior to their move to the UK and liaising with their other advisers to solve various cross border issues.
Stamp Duty Land Tax
We advised as to the potential SDLT liability on the purchase of a high-value property by a non-resident who was planning to become UK resident.
Effect of Covid-19 on Residence
We advised on the UK residence status of a US resident individual who had worked in the UK because of the border closures caused by the Coronavirus pandemic.
Large farming and entrepreneurial family
We reviewed the existing estate and succession planning for a large farming and entrepreneurial family. This involved a comprehensive review of both agricultural property relief and business property relief highlighting areas of concern and how the family’s situation could be improved.
We advised a UK resident and domiciled individual on becoming non-UK resident on his move to Spain before making a significant capital gain. This included liaising with Spanish advisers, advising on the practicalities of the move and providing continuing advice on subsequent UK investments.
We devised an estate planning strategy for the owners of a family business to reduce the family’s Inheritance Tax exposure. This involved liaising with overseas advisers to deal with various cross border tax and trust issues which we had identified.
UK Residence Status
We advised a Kuwaiti resident individual on his UK residence status taking account of the exceptional circumstances exception. After a short visit to the UK he had been unable to leave for many months because of the Covid-19 pandemic.
We advised a client on the imposition of the ATED Charge following his acquisition of a company owning a residential property which had originally been held as trading stock but was later to be let. This included advice on the availability of property rental business relief including the practical steps to be taken by the company. Advice was also provided on the filing of a Relief Declaration Return and an amended return for a previous chargeable period.
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