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23 April 2020
The Honourable Society of Gray's Inn,
London, UK

NON-RES AND NON-DOMS – VITAL TAX AND REGULATORY UPDATE

Budget 2020, Excluded property, Tarnished golden trusts, ITA 2007 s720, DAC6, GDPR and trustees, TRS, Hybrid companies, Trust audit

Led by Patrick Soares

Why You Should Attend?

New rules penalise non-doms: 

Discover how to navigate the new regime.

The recent non-doms rules clearly penalise non-doms:

  • the number of people claiming non-doms in the UK fell by 13%
  • tax receipts from non-doms fell from £9.5bn to £7.5bn




But the numbers are not as radical as they at first seem, as those 'deemed domiciled' for tax purposes:

  • are not counted as non-doms
  • nor are their taxes counted as non-dom revenue
  • yet those taxes are still payable to the exchequer

This event will help you determine:

  • how best to navigate the new non-dom environment
  • the impact of the changes to remittance basis
  • the way forward now we have certainty re:
    • Brexit
    • UK election


  • There is a look-through of foreign companies which hold UK land for some taxes but not others
  • Many settlements do not realize they are liable for the 10 year anniversary charges
  • The ATED applies to some bodies but not others
  • Taxpayers are falling within the POAT without realising it
  • Treaties override s3 CGT charges and loans are ignored
  • Some taxes attach to share sales in foreign companies, others do not
  • HMRC is attacking structures which in the past they have left alone
  • With the worldwide disclosure now taking place:
    • taxpayers who did not disclose under the RTC provisions are now getting letters from HMRC
    • how should they reply?

Despite the many traps, there are optimum positions which can be taken.

Therefore, the aim of this practitioner conference is:

  1. to ensure you avoid the traps and penalties
  2. to help you to adopt the optimum positions in the circumstances
  3. to illustrate this guidance through case study examples
  4. to bring you the expert advice of those involved in the legislation

What Will be covered

Key Session Highlights - Regulatory
  1. Budget Update 
  2. The Finance Bill 2020
  3. Update on S720 Following Recent Case Law
  4. GDPR: How it Affects Overseas Trustees
  5. Brexit and the Freedoms
  6. The TRS in Practice
Key Session Highlights - Tax (1)
  1. Brownbill’s Vital Trust Audit
  2. Routier and the Freedoms
  3. IHT Update
  4. Succession & Cross-Border Tax Issues
  5. The Loan Charge Changes Following the Morse Review
  6. Loan Problems in General
Key Session Highlights - Tax (2)
  1. Excluded Property & The New Legislation
  2. DAC6
  3. OIGs and Protected Settlements
  4. Creating and Taking Care of Golden Trusts
  5. Hybrid Rules on Royalties and Interest
  6. Update of What is Happening in Practice

Special Feature for all Registered Delegates

On the day all registered delegates will receive a 100 page tax memorandum by Patrick Soares on the proposed change

Engage in discussion with the speaking panel who are at the forefront of all these major changes. 

This conference gives you the up to date position on what should be done. Miss this one at your peril!

Previous Delegates Include

Saffery Champness

Moore Stephens

Francis Clark

Wedlake Bell

KPMG

Buzzacott

Cornerstone Tax Limited

Forsters

Frank Hirth

Mazars LLP

BDO

Smith & Williamson 

Fortress Management Services Ltd

Salamanca Group Trust & Fiduciary 

Gabelle LLP

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