Tax consulting that suits your needs
INVESTIGATIONS & DISCLOSURES
We have experience in dealing with complex disclosures to HMRC including under the Worldwide Disclosure Facility as well as Code of Practice 8 and Code of Practice 9 (tax fraud) investigations. We have also used the Let Property Campaign to help regulate a client's tax position with respect to undeclared rental income.
With the introduction of the Common Reporting Standard or 'CRS' (the automatic flow of financial information between signatory countries), there will be a significant increase in investigations and enquiries into individual's tax affairs (especially those with foreign assets). We are experienced in dealing with such enquiries and investigations and have a good relationship with HMRC. We work closely with former HMRC lawyers to ensure that we have a better understanding of the tactics and processes that HMRC use.
In addition, as more and more foreign professional companies suffer data breaches (Panama papers - Mossack Fonseca, Paradise Papers - Appleby, the Falciani documents - HSBC), clients need to be confident that if they are caught up in such breaches that they either can defend their position or they make a disclosure to HMRC as quickly as possible - we can assist in both circumstances.
We can prepare the simplest to the most complex tax returns and everything in between. We have a pricing structure to meet all needs.
Many of our clients have a foreign element to their income and we are used to preparing tax returns to ensure all foreign tax credits are properly claimed so that tax is not paid twice on the same income in two different jurisdictions.
We have a lot of experience working for US citizens who are resident in the UK and who have reporting obligations in both the US and UK. Whilst we do not yet prepare US returns, we work closely with US advisors and understand the US filing process and requirements.
We can prepare the financial accounts and corporate tax returns for SMEs and OMBs.
We advise UK resident non-domiciliaires on the remittance basis of taxation. When the remittance basis charge becomes payable we can advise whether it is more cost effective for the client to opt to be taxed on the remittance basis or the arising basis of taxation (i.e. include all worldwide income and gains on the UK tax return).
We advise on the settling of excluded property trusts for inheritance tax purposes if a client is close to or likely to become deemed domiciled for UK IHT purposes. These trusts ensure that non UK situate assets that are settled into an excluded property trust do not form part of the client's estate for inheritance tax purposes.
We advise on pre-arrival planning for clients who seek advice before becoming tax resident in the UK, to ensure that their bank accounts and assets are as structured in the most tax efficient way.
We advise UK resident beneficiaries of their reporting requirements in respect of their interests in offshore trusts, explaining the complex UK anti-avoidance legislation relating to offshore trusts in a clear and succinct manner.
We assist offshore trustees with the practicalities of holding assets on trust for UK resident beneficiaries. We also advise trustees with the practicalities of running a trust (specifically more complex structures such as Private Trust Company or 'PTC' structures), and can provide operating manuals to assist trustees with the day to day running of the trust according to the trust deed.
We offer a top-to-tail trust review service to ensure that trusts are being run correctly which includes a review of underlying trust assets and how they are held, a review of trustee resolutions and underlying company board meeting minutes. In addition, as part of the review we can ensure the trust structure still meets the needs of the relevant parties and is being run in the most tax efficient manner for UK tax purposes.
STATUTORY RESIDENCE TEST & TREATY RESIDENCE
Clients who are coming to the UK or leaving the UK will need advice on the UK tax residency rules. In 2013 the UK government introduced the Statutory Residence Test ('SRT') which will provide each individual with a definitive answer to their residence status. The test itself is quite convoluted. We provide clear advice to clients with respect to their UK residence position and set out what they must do to ensure that they do not become UK tax resident, or indeed, what they must do to become UK tax resident.
Where clients are tax resident in two jurisdictions under the relevant domestic laws, it will be necessary to refer to the double taxation treaty between the UK and the jurisdiction in point (to the extent there is one). We have a wealth of experience advising clients with respect to their 'treaty' position' in order to determine which jurisdiction has primary taxing rights.