Globally Speaking
Wedlake Bell’s insights on issues affecting the international private client community
Globally Speaking is a biannual ebulletin from our Private Client team on a wide range of trending issues relevant to the private client, family office and trustee community with an offshore focus.
Specialist lawyers within our Private Client team provide commentary on issues involving:
- non-UK domiciled individuals and/or non-UK resident individuals with UK investments, from a UK tax and estate planning perspective;
- offshore trusts and other wealth planning structures;
- family offices for internationally-mobile families;
- ownership of high-value UK property;
- art and luxury assets;
- succession planning for global family businesses; and
- family governance, and responsible and sustainable stewardship, of internationally-held wealth.
Our clients’ cross-border needs on these themes inevitably involve legal advice on more than one area of law and we provide combined thought leadership across the firm’s four practice groups model, bringing in expertise from lawyers including those in our Residential Property, Commercial Property, Family, Corporate, Disputes, Insolvency and Restructuring, and Pensions teams.
Our latest Globally Speaking commentary is below.
Globally Speaking
Globally Speaking – May 2024
In this “stop press” edition of our Globally Speaking e-bulletin, we provide our thoughts on how the announcement this week of the date for the next general election on 4… Read more →
Globally Speaking
NON-DOM ANALYSIS: A POLITICAL BUDGET
Although rumours abounded in the two weeks leading up to the Chancellor’s Spring Budget speech on 6 March 2024 about potential reforms to the tax regime for non-UK domiciled individuals… Read more →
Globally Speaking
Non-dom analysis: overview of reforms
What was announced by the Chancellor in the Spring Budget on 6 March 2024 were wide-ranging reforms to the UK’s tax regime for non-UK domiciled (“non-dom“) individuals (“non-dom regime“). This… Read more →
Globally Speaking
Non-dom analysis: the first four years
I am a recent arriver in the UK. Will the new exemption regime apply to me? In the 2024 Spring Budget on 6 March 2024, the Chancellor announced that the… Read more →
Globally Speaking
Non-dom analysis: pre-arrival
I am planning to move to the UK – how will the new residence-based exemption rules apply to me and is there anything I need to do before moving? It… Read more →
Globally Speaking
Non-dom analysis: UK returners
I am a British expat living abroad. What should I be thinking about? British expats are typically UK domiciled (“UK dom“) but non-UK resident for UK tax purposes. The extent to… Read more →
Globally Speaking
Globally Speaking: Welcome from the Editor
Welcome to the March 2024 special edition of our international e-bulletin for private client, family office and trustee clients and contacts. Although rumours abounded in the two weeks leading up… Read more →
Globally Speaking
Update on the Register of Overseas Entities (“ROE”)
Have you filed your 2024 ROE update statement? What do the March 2024 ROE regulations mean for you? If you have real estate in Scotland, are you ready for 1… Read more →
Globally Speaking
NON-DOM ANALYSIS: TRUSTS
Are offshore trusts still efficient for UK income tax and capital gains tax? In this article we consider how the 2024 Spring Budget announcements are likely to impact offshore trusts… Read more →
Globally Speaking
Non-dom analysis: inheritance tax (“IHT”)
How are the IHT rules changing? In the Spring Budget on 6 March 2024, the Conservative government proposed a residence-based test for IHT – as opposed to one based on… Read more →
Globally Speaking
Non-dom analysis: UK leavers
I am UK resident but non-UK domiciled (“RND″) and have been in the UK for longer than ten years. Should I stay or should I go? Income and capital gains… Read more →
Globally Speaking
Non-dom analysis: year four onwards
I have been UK resident for longer than four years, and am claiming the remittance basis. What should I be thinking about? In his Spring Budget of 6 March 2024,… Read more →
Globally Speaking
The Register of Overseas Entities: the Update Season?
Alongside the shine and sparkle of the festive season – with its flurry of activity spilling beyond crowded shopping malls and into living rooms (and offices) warmly lit by the… Read more →
Globally Speaking
Shareholder Disputes: How did it come to this?
I probably won’t live this down but I have a musical guilty pleasure in country and western, specifically Taylor Swift. I didn’t think that weakness would ever overlap with work.… Read more →
Globally Speaking
The Art of Being a Trustee: Holistic Decision-Making
At an increasing rate, trustees are finding themselves in a position where they are entrusted with administering trust funds that comprise (directly or indirectly, via underlying companies) luxury assets, such… Read more →
Globally Speaking
Tired of London (the UK), Tired of Life: a Perspective on Domicile
“Why, Sir, you find no man, at all intellectual, who is willing to leave London. No, Sir, when a man is tired of London, he is tired of life; for… Read more →
Globally Speaking
(US) Buyer Beware
Caveat Emptor translated from Latin means “let the buyer beware”, the saying typically afforded to buyers of residential property in the UK on the basis that they buy at their… Read more →
Globally Speaking
Should I stay or should I go? (The Clash 1981)
The favourable remittance basis of taxation available to those who are classified as non-domiciled but resident in the UK can trace its roots back to the late 18th century and… Read more →
Globally Speaking
Welcome from the Editor – Autumn 2023
Welcome to the September 2023 issue of our international e-bulletin for private client, family office and trustee clients and contacts. The UK politicians seem to have come back from their… Read more →
Globally Speaking
The Register of Overseas Entities and the Verification Conundrum
The Economic Crime (Transparency and Enforcement) Act 2022 (“ECA”) introduced a register of overseas entities (“ROE”) and was passed on 15 March 2022 after a fast-tracked legislative process following events… Read more →
Globally Speaking
Lost in the Pond
You are an American in the UK. You have not quite been cured of your American accent (your British spouse is working on this), but you have been in the… Read more →
Globally Speaking
Success(ion) Beyond the Balance Sheet
As family business advisers we are in the enviable position of sharing the journey of our clients as their businesses expand and take them into new territories. We have recently… Read more →
Globally Speaking
Finance Bill 2022/23 – a Private Client Perspective
The UK’s Finance Bill 2022/23 was published in draft on 20 July 2022. It was, as predicted, relatively light on measures affecting private clients. Consultation responses on the draft legislation… Read more →
Globally Speaking
An Update Regarding Digital Assets
Market crashes, bankruptcy filings, government reforms and lawsuits on the blockchain: the world of digital assets seems to change faster each day. Its relationship with the UK tax system is… Read more →
Globally Speaking
HMRC Campaign Regarding Property Holding Companies
This month, HMRC will start a campaign targeting foreign companies holding UK properties. This follows HMRC saying that it has reviewed the public Land Registry records and other sources, to… Read more →
Globally Speaking
French Nationals in the UK: Still Mobile, Still Attracted?
The French community of London is a highly organised and motivated community with a developed social and professional ecosystem that actively supports business, entrepreneurs and wealth creation. For those not… Read more →
Globally Speaking
PRIVACY AND PROPERTY – Recent legal developments increase the transparency of non-UK trusts and structures holding interests in UK property
Increasing the transparency of UK property ownership is part of a wider drive by the UK government to combat money laundering, tax evasion and fraud. There have been three recent… Read more →
Globally Speaking
The UK Trust Register: a moving feast
The UK’s Trust Register legislation[1] (“the AML Regulations“) came into force on 26 June 2017 and established a central UK Trust Register, maintained by HM Revenue & Customs (“HMRC“). The… Read more →
Globally Speaking
Relevant Debts, Collateral and the Remittance Basis
In 2021, HMRC changed how they would treat the foreign income or gains of a UK resident remittance basis taxpayer when used as collateral for a relevant debt that is… Read more →
Globally Speaking
Flight to freedom?
Rewind to March 2020 and the whole world was gripped by the Covid pandemic; countries closed their borders in their droves, desperate to contain the spread of this deadly virus… Read more →
Globally Speaking
Is Bidenomics affecting US/UK tax and estate planning?
To understand Bidenomics you have to ask how this new approach has come about. The backdrop is failing traditional economic policy – such as tax cuts to boost growth, deregulation… Read more →
Globally Speaking
Lasting Powers of Attorney for International Clients
Making a Lasting Power of Attorney under the law of England and Wales (an “LPA“) – appointing someone to manage your affairs in England and Wales in the event of… Read more →
Globally Speaking
Capital Taxation
The UK’s Prime Minister, Boris Johnson, and Chancellor Rishi Sunak have confirmed that national insurance rises for working people and employers in the UK will go ahead as legislated for… Read more →
Globally Speaking
Quelle Surprise! Potential UK Taxes for French Property Owners
Legend has it that the two ends of the Channel Tunnel were 50mm apart when the French and English engineers met in the middle. For some, that reinforces the notion… Read more →
Globally Speaking
Family offices in a post-pandemic world
Over the last ten years, family offices have become an increasingly common way for families with significant wealth to use a traditional business structure (“the family office”) to centralise and… Read more →
Globally Speaking
“To tax or not to tax” that is the question…
So how is the UK government going to pay for the billions of Covid related borrowing without breaking manifesto pledges and marginalising traditional Conservative voters? With huge short-term deficits and… Read more →
Globally Speaking
International family businesses remain agile during the Covid-19 pandemic
Whilst we have all stayed put in recent months as a consequence of swathes of restrictions on global travel that have been in place at various times during the COVID-19… Read more →
Globally Speaking
Riding the Cryptowave with circumspection
With El Salvador recently announcing the formal adoption of Bitcoin as legal tender and central banks around the globe experimenting with their own digital currencies, it is no longer possible… Read more →
Globally Speaking
DISCLOSURE AND THE FAMILY TRUST
Once upon a time there were only two certainties, death and taxes – both highly relevant to private client legal advice. Now there is a third – ever increasing compliance… Read more →
Globally Speaking
Annual Residential Property Tax Update
In this article for Globally Speaking, we take a look at recent trends regarding the UK’s annual property company tax, ATED. What is ATED? ATED, or to give it its… Read more →
Globally Speaking
‘WHAT THE RIGHT HAND GIVES, THE LEFT TAKES AWAY’: SDLT SURCHARGE FOR FOREIGN BUYERS OF UK PROPERTY SET TO COME INTO FORCE
The title to this article refers to the recent actions of the UK government in relation to Stamp Duty Land Tax (“SDLT“). The government has given away, with the current… Read more →
Globally Speaking
Speculate to Accumulate: Rumours of Tax Rises and Reforms
Having quietened down since last year’s Autumn Budget was cancelled, the rumour mill regarding potential tax changes is experiencing a revival as we head towards the next Budget on 3… Read more →
Globally Speaking
Seeking Out the Silver Lining
Amidst unprecedented economic uncertainty, the value of many assets is significantly lower now than what it was in a pre-Covid world. UK residential property is no exception, with property prices… Read more →
Globally Speaking
IMPORTANT CHANGE TO UK TAX RULES FOR NON-RESIDENT LANDLORD COMPANIES
Earlier this month an important change to the taxation of income received by non-UK resident landlord (“NRL“) companies was introduced. Since 6 April 2020, NRL companies have been subject to corporation… Read more →
Globally Speaking
Budget 2020 Update
On 11 March 2020, Chancellor, Rishi Sunak’s first Budget, and the first following the United Kingdom’s departure from the UK, contained two tax announcements of particular interest to foreign investors… Read more →
Globally Speaking
Corb Your Enthusiasm Part 2 – Labour Manifesto Pledges Affecting Property Investors
In this follow up article (pre-election Part 1 here), we take a look at some of the measures in Labour’s recent manifesto affecting property investors. A comparison of the Labour, the… Read more →
Globally Speaking
‘Corb Your Enthusiasm’: Potential Reforms Under the Labour Government
In this instalment of Globally Speaking, we look at some of the reforms that could ensue if Labour Party under the leadership of Jeremy Corbyn were to enter into power… Read more →
Globally Speaking
SDLT SURCHARGE PROPOSAL GETS DELAYED AMID BREXIT FALL-OUT
In March this year we reported that the government had published details of its proposal to introduce a 1% Stamp Duty Land Tax (“SDLT”) ‘surcharge’ on foreign purchasers of residential… Read more →
Globally Speaking
Property, in an alternative asset class of its own
Who said, “Buy land, they’re not making it anymore”? Answer at the end of the piece, for those whose memories fail them… What “they” are making seems to be different… Read more →
Globally Speaking
NEW TAX YEAR BRINGS AN END TO ATED-RELATED CAPITAL GAINS TAX
6 April 2019 brought in the start of the new tax year and with it yet another change to the taxation of UK property – namely, a widening of the… Read more →
Globally Speaking
Tax charges for non-resident owners of UK property set to come into force
On the 6 April 2019 significant changes to the taxation of non-UK resident individuals and companies owning UK real estate will come into effect. At present non-resident owners are only… Read more →
Globally Speaking
Government publishes consultation on proposed SDLT surcharge for foreign residential property purchasers
On 11 February 2019, the government published details of its proposed 1% Stamp Duty Land Tax (“SDLT“) ‘surcharge’ for foreign purchasers of residential property in England and Northern Ireland. The… Read more →
Globally Speaking
Alert! New Tax charges for Non-Residents disposing of UK Commercial Property
Extension of capital gains tax to non-resident individuals and corporation tax to non-resident companies holding UK commercial property At present, non-UK resident individuals and companies holding UK commercial property are… Read more →
Globally Speaking
The proposed register of beneficial owners for overseas companies
The Department for Business, Energy and International Strategy recently published the government’s response to its “call for evidence” last year on proposals for a register showing who owns and controls… Read more →
Globally Speaking
Is it time to reform the property tax regime?
Although 2016 delivered a number of political surprises, the UK economy has shown tremendous resilience. However, the one issue that continues to exert influence on the property market is property… Read more →
Globally Speaking
Landlords must assume tax relief changes will come into force in April
Currently, buy-to-let landlords can deduct their finance costs, including mortgage interest, from their rental profits before calculating their taxable income. This has the effect of reducing the amount of income… Read more →
Globally Speaking
Property Taxes Are Killing The Golden Goose
The property industry has just been warned by Communities Secretary Sajid Javid to “keep an eye out” for changes to real estate taxation in this year’s Autumn Statement. Change is… Read more →