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Forward planning and the reduction in top rate of UK income tax

The 2012 Budget announced that the top rate of income tax is being reduced to 45% from 50% as of 6 April 2013.  In light of this, we are advising that some clients may wish to plan to take advantage of the reduction in the tax rate by deferring an income tax charge to the […]

HMRC Tax Return Initiative

If HMRC have sent you a Self Assessment tax return or notice to complete a tax return for 2009-10 or earlier and you have not yet taken any action, HMRC are offering a quick way to bring your tax affairs up to date.  Any person who has been sent returns or a notice to file […]

FBAR Federal Appeals Court upholds IRS position – Willfulness penalities enforced

Followers of the IRS cases against Americans with undeclared foreign assets have been waiting in anticipation for the federal courts to set the scope of the term ‘willfulness’ as it applies to the imposition of civil penalties to file the Report of Foreign Bank and Financial Accounts or FBAR.  Some guidance has now been provided […]

Ownership of UK Property

The 2012 Budget saw the introduction of the new Stamp Duty Land Tax (SDLT) charge of 15% (effective from 21 March 2012) where a property is purchased by a ‘non-natural’ person (such as a company, collective investment scheme and partnerships with a corporate partner) and the value of the property exceeds £2 million. Further, HMRC […]

Switzerland and Japan sign FATCA agreement

Recently, Switzerland and Japan announced they had signed agreements with the US to facilitate the implementation of FATCA reporting by institutions within their respective jurisdictions.  Instead of reporting all client data direct to the IRS, Swiss and Japanese financial institutions will be allowed to pass only a limited subset of client details to the IRS. […]

Update to UK Statutory Residence Test

[Update to the previously published entry “UK Statutory Residence Test to take effect April 2013.“ The number of days resident in the UK has changed from 10 days to 15 days.] The UK government has recently announced that it will legislate the statutory residence test (SRT) to take effect from 5 April 2013 and intends […]

National Taxpayer Advocate identifies challenges and issues for upcoming year to Congress

Last week, Nina E. Olson, the US National Taxpayer Advocate, released a report to Congress that identifies the priority issues the Taxpayer Advocate Service (TAS) will focus on during the upcoming fiscal year.  The report expresses concern about the of expired and expiring tax provisions on the taxpayer, the rise in tax fraud and tax-related […]

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