International Personal Tax Conference 2019
Our one day conference has been specially designed for tax specialists who require an in depth knowledge of current topical issues. Speakers will look at recent key changes together with other current issues to enable those attending to give the best possible advise to their clients.
The topics covered are:
- A Question of Domicile
- UK CGT and Non-Resident Persons
- Offshore Trusts
- Practical Issues Arising from Remittances
- Tax Traps and Points for Cross Border Employees
- Handling Enquiries, Disclosure Agreements & Evasion
- Statutory Residence Test
CPD hours: 6
Full conference agenda
Pat Nown, Mercia Group Ltd
Domicile plays a crucial role in determining the tax position of individual clients. This short session considers some topical issues concerning UK and non-UK domicile status including:
• How is domicile determined?
• What evidence exists for non- UK domicile status?
• UK or non-UK domicile spouse?
Marilyn McKeever, New Quadrant Partners
A review of the offshore trust world now that the new non-domicile rules are all in force, including;
• Overview of the new rules in practice
• The OIGS conundrum
• Residential property – inheritance tax, loans and collateral
• Fifth Money Laundering Directive
• Issues for US/UK clients
Pat Nown, Mercia Group Ltd
Prior to 6 April 2015 non-UK resident persons were mainly outside the scope of UK capital gain tax - an attractive proposition for both non-UK residents and UK residents seeking to avoid the tax. Significant developments in 2015 and 2019 now bring into charge UK residential and commercial property as well as certain indirect disposals which derive at least 75% of their value from UK land and buildings.
Pat will consider the details of these changes for non-UK residents including reporting and the issues which face the UK resident seeking to use this status to obtain advantage.
Kevin Offer, Hardwick and Morris LLP
The rules on what constitutes a remittance and the tax charge that arises are complicated with many traps for the unwary that have only increased following the introduction of the deemed domicile status for long term residents. This presentation will provide some practical examples of how remittances to the UK can arise, how careful planning can avoid a remittance occurring and how the value of a remittance may be calculated. Consideration will be given to assets held both by individuals and within trust/corporate structures
Anne Fairpo, Temple Tax Chambers
This session will consider the UK tax issues that can arise when employees are seconded to or from the UK, looking at income tax and national insurance on salary, benefits and options, as well as HMRC processes and procedures. Anne will also review the impact of general tax issues such as residence and domicile on such employees and - to the extent that crystal ball gazing permits! - the possible implications of Brexit on EU employment tax issues.
Gary Brothers, The Independent Tax & Forensic Services LLP
Gary will look at HMRC’s approach to investigations with a non-UK influence, such as the investigation on non-resident individuals, how to effect tax disclosures where non-UK income is involved and how HMRC approach tax evasion cases, particularly where income or assets outside the UK, have arisen. Real life case study background will be used to reinforce examples of current HMRC approaches.
The session will include:
• HMRC’s current offshore activities
• The effect of the Common Reporting Standard
• The picture post-Requirement to Correct
• RTC defences
• HMRC offshore disclosures – points to consider
Kevin Offer, Hardwick and Morris LLP
The introduction of the Statutory Residence Test from April 2013 brought a significant change into the taxation of internationally mobile individuals and as a result advisers need to be aware of the impact on their clients. This session is a refresher of the workings of the Statutory Residence Test and some of the practical issues that have come to light since its introduction.
• Reminder of the basics of SRT
• The application of the overseas hours test
• What is a home?
• UK workdays test
• Split year rules
• Traps and opportunities
Gary founded Independent Tax in 2013 to assist practitioners and their clients deal with HMRC in troublesome cases. As an ex-Inspector, he and his team are well experienced in all matters HMRC. With 30 years experience specialising in tax enquiries and disputes on both sides of the fence, Gary and his team boast now an enviable list of successes in dealing with HMRC for clients ranging from owner managed businesses through to high net worth individuals and larger companies.
Gary prides himself on his easy access, no nonsense style aimed at early and active engagement with HMRC to achieve early and cost effective resolution.
Pat joined Mercia in 2008 as a tax consultant lecturer bringing a wealth of experience with her. She originally trained and worked in the profession for Ernst & Young, Grant Thornton and KPMG before moving to the University of Derby as their senior tax lecturer. Her time at Derby included undergraduate and professional tax training as well as being involved in examinations and publishing projects for ACCA and other professional bodies.
This led to a ten year period with the Financial Training Company now Kaplan where she was Tax Product Director for the Midlands as well as becoming well known as a prominent exam based tax lecturer. She was also involved during this time with significant publishing projects for the company and other professional bodies.
Over her career Pat has been actively involved in the tax professional bodies including serving as a Council member for 12 years for the Association of Taxation Technicians.
Anne Fairpo, CTA (Fellow) is a barrister at Temple Tax Chambers. She advises a range of clients from listed multinationals to small start-ups on all areas of corporate tax, including cross-border taxation, and employment-related tax. She is a member and Past President of the CIOT Council and has authored many books, including Taxation of Intellectual Property (Bloomsbury Professional).
Kevin Offer is a Partner at Hardwick and Morris LLP. He is a chartered tax advisor and a fellow of the Institute of Chartered Accountants in England and Wales (ICAEW). Kevin heads up the tax offering at H&M with special emphasis on private client work and the taxation of high net-worth, mainly non-domiciled individuals, sportspersons and entertainers. He presents regularly at conferences both in the UK and internationally and is a member of the International Tax Planning Association, the International Tax Specialists Group and the International Taxation of Entertainers Group
Marilyn specialises in international and UK tax and estate planning, including personal and trust taxation, working principally with international individuals and families and the trustees of their trusts. She focuses on tax and estate planning for non-UK domiciled clients, which involves all aspects of offshore and onshore trusts and wills and the remittance basis of taxation. In particular, Marilyn works to resolve the issues which arise in families with both US and UK connections.
Marilyn is a member of the Law Society’s Tax Law Committee and regularly engages with HMRC on policy and new legislation in the offshore and non-domicile field. Marilyn combines her practice with sitting as a Judge on the First Tier Tax Tribunal.