Preface. ii 1 The New Residence Based Regime after Finance Act 2025. 1 1.1 Summary. 2 1.2 General. 3 1.3 The Relevant Legislation.
11 2 Specifics: Replacement of Special Rules Relating to "Domicile. 13 2.1 Summary. 13 2.2 General. 18 2.3 Chapter 1 of Part 2 of the Act: New rules for foreign income and gains of individuals becoming UK resident. 21 2.
4 Details of New Chapter 5 Part 8 ITTOIA. 39 2.5 Section 38 - The New Overseas Workday Relief. 81 2.6 Schedule 8 Relief on foreign employment income: consequential and transitional provision. 102 2.7 Abolition of the remittance basis. 119 2.
8 Application of Income Tax Acts in relation to deemed employment. 143 2.9 Rebasing of assets for CGT for some former remittance basis users. 224 3 Trusts: connected amendments, transitional provision etc. 231 3.1 Summary. 231 3.2 Further Review.
3-234 3.3 The Legislation - section 43. 235 4 Inheritance Tax. 367 4.1 Summary. 368 4.2 Some Relevant Legislation. 4-374 4.
3 Replacement of Domicile Test by Long-Term Residence Test - section 44 FA 2025 380 4.4 Long Term Residence and Excluded Property. 383 4.5 Position concerning settled property following move away from Domicile. 406 Appendix 2: ANNEXE. 460 Appendix 3: Inland Revenue Pamphlet IR 20 Extracts. 463 Appendix 4: Some Relevant Definitions. 475 5 Relief for New Residents for Foreign Gains.
480 5.1 Summary. 480 5.2 Introduction. 482 5.3 Finance Bill Committee. 483 5.4 Details of new schedule D1.
487 Appendix 5: Table of some relevant definitions. 505 6 Some first thoughts, and possibilities. 510 6.1 Summary. 510 6.2 Introduction. 513 6.3 Some approaches.
517 6.4 Putting in "firebreaks" - one other prophylactic to consider is the use of "firebreaks". 6-532 6.5 Restructuring arrangements including image rights and endorsement arrangements. 6-536 6.6 Using insurance for funding and or as a wrapper. 6-537 6.7 Starting the clock again.
6-539 6.8 Checking nationality etc and applicability of DDC. 6-546 6.9 Fragmenting and splitting ownership. 6-550 6.10 Fixing the value and giving away the value above that. 6-551 6.11 Double Death Conventions ("DDC") 6-561 6.
12 Conclusion. 604 Appendix 6: Some questions for clients?. 605 Appendix 7: Table of Situs of Assets. 606 Appendix 8: Jurisdiction Table. 625.