Introduction
HM Revenue & Customs (HMRC) made an unexpected announcement
on 4 August 2014 on the taxation of unremitted foreign income or
gains used as collateral for a loan enjoyed in the UK. As a result,
UK resident individuals who are not domiciled in the UK, generally
known as 'resident non-doms' (RND) on the remittance basis
(ie taxed on money brought into the country) could face an
unexpected and significant tax bill on the full balance of any
outstanding loan if such a loan has been enjoyed in the UK, whether
taken out in the UK or where the funds have been brought into the
UK to finance, for example, property or businesses in the UK.
Interpretation of the legislation
HMRC's previous interpretation
