Taxation of Non-Residents and Foreign Domiciliaries

Taxation of Non-Residents and Foreign Domiciliaries

16th Edition 2017/18 - Hard Copy


ISBN: 978-1-901614-70-1

Publication date: 28/11/2017

Price: £330.00

Taxation of non-Residents and Foreign Domiciliaries 16th Edition 2017/18


ISBN  978-1-901614-70-1


by James Kessler Q.C.



Publication date: 1 September 2017 (online edition) 28th November 2017 (paper edition)


Hard copy Price £330.00


Online  Price £110.00 plus VAT, online edition is only available to purchasers of the paper version of the current 16th edition .


About the author

James Kessler QC practises at the Tax Bar. He was appointed QC in 2003. He is also a member of the Bar of Northern Ireland.

James advises in particular on foreign domiciliaries, offshore entities trusts, wills and charities

Other areas of practice include prosecution of tax crime in complex cases, particularly along the avoidance/evasion faultline, and freedom of information.

James is one of the founders of the Society of Trust and Estate Practitioners, for whom he drafted the STEP Standard Provisions, and a fellow of the Chartered Institute of Taxation. James has received the Geoffrey Shindler Award for Outstanding Contribution to the Profession.



Volume 1

1. Foreign Domicile: Tax Policy and Reforms

2. Tax avoidance: Public debate

3. Domicile

4. Deemed domicile 

5. Residence of Individuals

6. Residence of Trustees

7. Treaty-Residence

8. Exit Taxes

9. Split Years: Arrival and Departure

10. Temporary Non-residence: Post-2013 Departures

10A Temporary Non-residence: Pre-2013 Departures published online only1

 11. The Remittance Basis

Volume 2

12. The Meaning of Remittance

13. Remittance Reliefs

14. Mixed Funds 

15. Income Categories and Sources

16. Trading Income

17. Trading in land

18. Entertainers and Sportspeople

19. Property Income

20. Deduction of Interest from Property Income

21. Interest Income

22. Exempt Interest of Non-Residents

23. Dividend Income

24. Royalty Income  

25. Misc Sweep-Up Income

Volume 3

26. Employment Income 

27. Travel Expenses: Employment Income Deduction

 28. PAYE

29. Employment Income: DT Relief

30. Pension and Annuity Income

31. Discretionary Trusts: Income Tax

32. IIP Trusts: Income Tax

33. Settlor-Interested Trusts

34. Transfer of Assets Abroad: Introduction

35. Transfer of Assets Abroad: Transferors

36. Transfer of Assets Abroad: Non-transferors

37. Transfer of Assets Abroad: Relief From Overlapping Charges

38. Transfer of Assets Abroad: Motive Defence

Volume 4

39. Life Policies and Contracts

40. Offshore Funds: Definition

41. Offshore Income Gains

42. Income from Offshore Funds

43. Accrued Income Profits

44. Deeply Discounted Securities

45. Unit Trusts

46. Intermediated Securities

47. Partnerships

48. Non-Residents Income Tax Relief

49. Collection of Tax from UK Representatives

50. Investment Manager Exemptions

51. Investment Management Fees & Carried Interest

52. Loans from Non-Resident Companies

53. Rates of Tax

54. Personal Allowances and Annual Exemptions

55. National Insurance Contributions

56. Gains of UK Residents

57. Gains of Non-Resident Settlor-Interested Trusts: s.86

58. Capital Payments from Non-Resident Trusts: s.87

59. Borrowing by Non-resident Trusts: Sch 4B

60. Protected Trusts

61. Sub-Funds

62. Gains of Non-Resident Companies

63. Capital Losses

Volume 5

64. Foreign Currency Issues

65. Unremittable Assets

66. Double Taxation Arrangements: Introduction

67. DTA Anti-Abuse Rules 

68. Foreign Tax Credit Relief

69. EU Law and UK Taxation

70. Excluded Property: Definition

71. Excluded Property Exemptions

72. Wills and IOVs

73. Reservation of Benefit

74. Inter-Trust Transfers: IHT

75. IHT Deduction for Debts

76. IHT Double Taxation Treaties - Introduction

77. IHT DTAs: India, Pakistan, Italy, France


79. IHT DTA: Switzerland

80. IHT DTA: Netherlands

81. Foreign IHT Credit Relief

82. Marriage to Non-dom or Non-resident

83. Private Residence Relief

84. Residential Property of Non-Residents: NRCGT

85. Family Home and Chattels: Benefit in Kind Charges

86. Corporate Residential Property

87. Residential Property: IHT

Volume 6

88. Pre-Owned Assets

89. Joint Accounts

90. Estates of Deceased Persons: CGT

91. Estates of Deceased Persons: Income Tax

92. Who is the Settlor?

93. Trust with Two or More Settlors

94. Situs of Assets for IHT

95. Situs of Assets for CGT

96. Foreign Entities

97. Hybrid Entities

98. Control Connected Close and Related Expressions

99. Permanent Establishment and Branch/Agency

100. Disclosure and Compliance

101. Disclosure on Death

102. Disclosure of Offshore Trusts 

103. Criminal Law and Professional Conduct

 Appendix 1: Common Expressions

Appendix 2 Consideration, Arm's Length, Full Value

Appendix 3: Associated Operations: IHT

Appendix 4: Construction of Deeming Provisions 

Appendix 5: What do we mean by “Real”?

Appendix 6: Parliamentarians

Appendix 7: Visiting Forces

Appendix 8: How to Improve Residence and Domicile Taxation

Appendix 9: Reform of Offshore Anti-Avoidance Rules

Appendix 10: UK Arrival or Departure: Tax Checklist

Appendix 11: Welsh Devolution