Offshore Tax Planning, Tax Incentives, and Guides for Expats

Offshore Tax Planning, Tax Incentives, and Guides for Expats Need a little extra advice on how to get strategic with offshore tax planning? By becoming non UK resident or moving your assets offshore it is possible to snip your tax bill to zero. However, there are also many pitfalls to avoid.

Non-Resident & Offshore Tax Planning is a useful option for anyone who:

Anyone wanting to become non-resident to avoid UK income tax and capital gains tax.
Foreign nationals (non-domiciles) who want to make the most of their special tax status.
Anyone interested in using offshore trusts and companies to pay less tax.
Anyone living or working abroad.

However, if you are considering this be warned! The UK's offshore fund tax rules are changing. Subject to the outcome of a final consultation, with effect from 1 October 2009, offshore funds will be able to elect for 'reporting-fund' status. This will be of major importance in enabling UK-resident investors in offshore funds to attain favourable capital gains tax (CGT) treatment for their investment in such offshore funds. It should provide a less intrusive certification process and greater certainty for funds and their investors.

Under the existing regime, unless an offshore fund is certified by HM Revenue & Customs (HMRC) as a distributing fund, UK investors will be subject to income tax rather than CGT on any gain arising from the disposal of their interests in the fund. Since the current highest marginal rate of income tax of 40% is significantly higher than the flat CGT rate of 18%, obtaining distributing-fund status is of utmost importance to most UK individual investors. This significance will increase further in future if the Government's plan to increase the highest marginal income tax rate to 45% with effect from 6 April 2011 is implemented.

A comparison of the UK and the US tax treatment of investments

Friday, 28 August 2009 11:30

International taxation

Investors with UK and US exposures need to take particular care in selecting their investments. By Samantha Morgan, Partner, Jay Krause, Partner and Philip Munro, Associate, Withers LLP.

Globalisation has led to many successful families and their interests becoming international in profile. Accordingly, tax and succession planning for many families will now have a cross-border element which can mean that the tax position of family investments needs to be considered from the perspective of more than one tax regime. As different tax systems can treat certain investment types very differently, international families need careful advice to ensure that their investment strategy is tax efficient across the relevant jurisdictions. As a result of historically close ties, many successful families have both UK and US tax exposures requiring them to develop investment strategies that are tax efficient for both tax regimes. We compare below the US and UK tax treatment of certain investment types as an example of the form of cross-jurisdictional tax analysis that may be required for international families.

UK Inheritance tax

Friday, 26 June 2009 11:42

UK IHT planning for non UK residents
Effective planning is essential to minimise the impact of this potentially substantial levy

by Susan Midha, Partner, Private Client Department, Adams & Remers Solicitors

Raising tax on gifts or estates is neither universal nor, in the countries where it occurs, popular. To many, it seems to be an unacceptable further levy on assets which have already suffered tax and many countries have abandoned the idea. The UK, though, still clings to the concept of Inheritance Tax (IHT) and it is likely to survive even the change of Government which is expected to occur within the next year.

Milestone - Question and Answer

Friday, 26 June 2009 11:49
Milestone - Question and Answer Milestone is a boutique international tax practice based in Mayfair. They provide tax advice to a broad range of clients from corporates with international finance activities to investment funds to high net worth individuals. Read more...

Investment and Tax Clinic

Friday, 26 June 2009 11:24

Investment and Tax Clinic
The Investment International Investment and Tax Clinic
Miles Dean and Andrew Murray, partners in Milestone, provide advice in this month’s clinic

Milestone is a boutique international tax practice based in Mayfair. They provide tax advice to a broad range of clients, from corporates with international activities to investment funds to high net worth individuals.