Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 09 MARCH 2018

Are You Ready For 5 April?

Withers LLP
Withers LLP
Contributor
Withers LLP

Withers LLP

Withers is an international law firm focused on the personal, business and philanthropic interests...

View firm profile
Explore more from Withers LLP

One of the many reasons why the UK is still a great place to live is the ability for many UK residents to establish trusts funded with non-UK assets in order to take advantage of various tax benefits.

United KingdomTax
Jaime McLemore
Jaime McLemore
Author LinkedIn connections

One of the many reasons why the UK is still a great place to live is the ability for many UK residents to establish trusts funded with non-UK assets in order to take advantage of various tax benefits. There is a lot of opportunity for UK income tax planning using these trusts and my UK colleague Lara Crompton does a very good job of explaining those in her article ________. But I want to focus on the Americans in the UK, and specifically those Americans who may already be in or are approaching their 15th year of residency in the UK.

We know that the UK non-dom regime changed significantly in 2017 with more changes yet to be fully implemented. One change is how long a non-domiciled individual can reside in the UK before becoming deemed domiciled for UK inheritance tax purposes. The old rule stated that an individual would become deemed domiciled in their 17th (out of 20) years of residency. Now the rule is that an individual will be deemed domiciled after residence in

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

UK ‘Windfall’ Bank Tax Would Worsen An Already Complex System

UK banks face the prospect of a new windfall tax as campaigners push for additional levies on strong reported profits, while industry leaders warn of potential consequences for lending, investment, and the UK's position as a global financial centre. This analysis examines the practical implications of adding another layer to an already complex sector-specific tax regime that includes corporation tax, banking surcharge, and bank levy.
United KingdomTax
RPC
RPC
Article

Frequently Asked Questions About IRS Clearance And Form 706-NA

UK executors and beneficiaries dealing with US assets face significant delays in obtaining IRS Transfer Certificates, with waiting times now extending to two or three years. This comprehensive FAQ addresses the critical questions surrounding Form 706-NA applications, US estate tax requirements, and the practical challenges of administering estates containing US shares and investments when the deceased was not a US citizen.
GlobalTax
Lester Aldridge LLP
Lester Aldridge LLP
Article

Tribunal Limits HMRC's Schedule 36 Powers In Transfer Pricing Case

When HMRC issued an information notice demanding a UK subsidiary's US parent company financial statements in a transfer pricing enquiry, the First-tier Tribunal had to determine whether such documents were reasonably required and whether the subsidiary had the power to obtain them. The case examines the boundaries of HMRC's information-gathering powers and the practical limits of corporate group relationships.
European UnionTax
RPC
RPC
Article

Transfer Pricing Enquiries: HMRC’s Approach And Recent Cases

Transfer pricing litigation in the UK has historically been rare, but recent procedural cases reveal HMRC's increasingly aggressive approach to enquiries. With average enquiry durations now exceeding 40 months and transfer pricing yield surging to £3.4bn, understanding the legal boundaries of information requests and closure notice applications has become critical for multinational groups facing contentious disputes.
United KingdomTax
Macfarlanes LLP
Macfarlanes LLP
Article

A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.
United StatesTax
Withers LLP
Withers LLP
Article

Navigating Florida’s New Trust, Probate And Series LLC Statutes

Florida has enacted significant statutory changes affecting trust administration, probate procedures, and business entity formation. These reforms introduce streamlined nonjudicial processes for trustee discharge, expand access to simplified probate administration, and establish a new framework for protected series LLCs that offers enhanced asset protection and operational flexibility for estate planners and business owners.
United StatesWealth Management
Withers LLP
Withers LLP
Article

Subscription Contracts: What Businesses Need To Know About The New UK Cancel Culture

The UK government has accelerated the implementation of new subscription contract rules under the Digital Markets, Competition and Consumers Act 2024, moving the enforcement date to January 2027. These regulations introduce stricter transparency requirements at sign-up, mandatory cooling-off periods including a new renewal cooling-off window, and simplified cancellation processes designed to eliminate 'subscription traps' that lock consumers into unwanted recurring payments.
United KingdomConsumer Protection
Withers LLP
Withers LLP
Article

Flexible Working In 2027: The UK Government Reveals Further Details Of Upcoming Reforms

The UK government has published its response to consultation on flexible working reforms, introducing a new reasonableness test for employers refusing requests from 2027. The reforms will require employers to meet with employees before rejecting applications and explain why refusal is reasonable, while consultation data reveals significant gaps between employer and employee perceptions of the current system.
United KingdomEmployment and HR
Withers LLP
Withers LLP
Article

Navigating Japan's Foreign Investment Rules: Key Requirements And The 2026 Reform Update

Japan's Foreign Exchange and Foreign Trade Act amendments, promulgated in June 2026, introduce significant changes to foreign direct investment screening procedures. These modifications expand regulatory oversight to include indirect acquisitions, mandate reporting of risk mitigation measures, and grant authorities enhanced powers to address national security concerns even after transactions are completed.
JapanGovernment, Public Sector
Withers LLP
Withers LLP
Article

Over Two Thirds Of Charities Report A Rising Demand For Services Over The Past Year

The Charities Aid Foundation's World Giving Report reveals that two-thirds of charities are experiencing increased demand for services while facing significant funding challenges. With restricted funding streams and depleting reserves, many organizations struggle to maintain operations, raising critical questions about the sector's long-term sustainability and the need for more flexible funding approaches.
United KingdomCorporate/Commercial Law
Withers LLP
Withers LLP