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Guide to US/UK Private Wealth Tax Planning

Corporate: Withers LLP By: Robert L Williams
Media of Guide to US/UK Private Wealth Tax Planning
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Published: 28-07-2016
Format: Paperback
Edition: 2nd
Extent: 816
ISBN: 9781847665096
Imprint: Bloomsbury Professional
Dimensions: 234 x 156 mm
RRP : €160.00

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Loren Epson

About Guide to US/UK Private Wealth Tax Planning

This unique book is a concise but complete tax planning manual for those advising high net worth individuals of the UK, US or any other nationality who have UK or US residence, assets or family members.

Guide to US/UK Private Wealth Tax Planning covers all the information and legislation you are likely to require when advising clients exposed to both UK and US taxation, providing you with:

A quick reference summary of the UK and US rules applicable to your clients;
A comprehensive summary of available unilateral and treaty planning techniques to avoid US estate tax or UK inheritance tax for clients who are non-domiciliaries of the UK or US;
Optimal income and gains tax planning for foreign trusts with UK or US beneficiaries;
Integrated UK and US tax planning solutions for clients exposed to both UK and US tax.

Previous edition ISBN: 9781845920272

Table Of Contents

Part I: Outline of Relevant Taxes
Section 1: Principal taxes
Chapter 1 Taxation status in the US: overview
Chapter 2 US: transfer tax system
Chapter 3 US: transfer taxes: marital deduction
Chapter 4 US: state death and inheritance taxes
Chapter 5 US: tax on capital gains
Chapter 6 US: tax basis rules for gifts and bequests
Chapter 7 US: income tax
Chapter 8 Overview of principal UK taxes
Chapter 9 UK: inheritance tax on individuals
Chapter 10 UK: pre-owned asset tax
Chapter 11 UK: income tax
Chapter 12 UK: capital gains tax
Chapter 13 UK: the arising basis and the remittance basis
Chapter 14 UK: corporation tax
Chapter 15 UK: annual tax on enveloped dwellings
Chapter 16 UK: stamp duty land tax
Section 2: Tax status and basis of taxation
Chapter 17 US: citizenship
Chapter 18 US expatriation
Chapter 19 US: income tax residence rules for foreign nationals
Chapter 20 US: trust residence (income tax)
Chapter 21 US: income taxation of non-resident aliens and foreign corporations
Chapter 22 US: domicile and transfer taxation of non domiciliaries
Chapter 23 US: situs of assets taxable to non domiciliaries
Chapter 24 Taxation status in the UK: overview
Chapter 25 UK nationality
Chapter 26 UK: domicile
Chapter 27 UK: residence of individuals
Chapter 28 UK: residence of trustees
Chapter 29 UK: residence of companies
Chapter 30 UK: situs
Section 3: Trust and estate taxation
Chapter 31 US: transfer taxes on trusts
Chapter 32 US: grantor trusts
Chapter 33 US: non-grantor trusts
Chapter 34 US: special needs trusts
Chapter 35 US: intentionally defective grantor trusts
Chapter 36 Crummey Powers
Chapter 37 US: qualified personal residence trust
Chapter 38 US: taxation of deceased's estates and beneficiaries
Chapter 39 GRATs
Chapter 40 UK: inheritance tax on trustees
Chapter 41 UK: trusts – income tax and capital gains tax
Chapter 42 UK taxation of personal representatives
Section 4: Taxation on corporations
Chapter 43 US and Treaty entity classification rules – corporations, partnerships and branches
Chapter 44 US: private trust companies
Chapter 45 US: passive foreign investment companies
Chapter 46 US: controlled foreign corporations
Chapter 47 US: partnership interests of non-US persons
Chapter 48 US: non-US corporations and estate tax
Chapter 49 US: treatment of non-US entities
Chapter 50 UK: UK tax classification of non-UK entities
Chapter 51 UK: companies
Chapter 52 UK controlled foreign companies
Chapter 53 UK: partnerships
Chapter 54 UK: offshore funds and offshore income gains
Section 5: Charities
Chapter 55 US charities
Chapter 56 UK: taxation of gifts to charity
Section 6: Insurance
Chapter 57 US: life insurance policies
Chapter 58 UK: qualifying and non-qualifying insurance policies
Chapter 59 UK: personal portfolio bonds
Section 7: Compliance
Chapter 60 US compliance: 12 foreign tax reporting forms
Chapter 61 US: withholding tax regulations
Chapter 62 US FATCA
Chapter 63 US requirement for reporting of foreign financial accounts FBAR and tax FBAR annual reports
Chapter 64 US offshore voluntary disclosure program
Chapter 65 US foreign trusts' reporting requirements
Chapter 66 UK: self assessment
Chapter 67 UK: trust reporting
Chapter 68 UK: tax information exchange measures
Chapter 69 UK: general anti-avoidance legislation
Section 8: US-UK Treaties
Chapter 70 The US-UK Income Tax Treaty
Chapter 71 The US/UK estate and gift tax treaty
Part II: Planning
Chapter 72 UK: pre-immigration planning
Chapter 73 US: pre-immigration planning
Chapter 74 Expatriation
Chapter 75 Lifetime giving
Chapter 76A Spouses and civil partners: lifetime planning
Chapter 76B Spouses and civil partners: testamentary planning
Chapter 76C Spouses and civil partners: jointly-owned property
Chapter 76D Divorce planning
Chapter 77 Insurance planning
Chapter 78 Trusts and partnership planning: forming trusts and other entities
Chapter 79 Trusts and partnership planning: planning with existing trusts
Chapter 80 Wills
Chapter 81 Probate and the administration of estates: tax issues for personal representatives
Chapter 82 Post-death variations and disclaimers
Chapter 83 Giving to charity
Appendix I: US Tax Tables 2016/2017
Appendix II: UK Tax Tables 2016/17
Appendix III: 2001 United Kingdom-United States Income Tax Treaty (conformed to include the 2002 Protocol)
Appendix IV: 1978 United Kingdom-United States Estate and Gift Tax Treaty
Appendix V: The American Diaspora, Innocents Abroad
Appendix VI: FATCA, IGAs, and the OECD CRS: The Future Landscape for Trusts
Appendix VII: Trust and Company Strategies to Avoid Penal US Tax Exposures.

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