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Taxing matters

14 May 2009 / Peter Vaines
Issue: 7369 / Categories: Features , Tax , Commercial
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Peter Vaines reports on life, tax & quantitative pleasing

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HMRC has published its long-promised guidance on residence which replaces IR20 and all other Revenue guidance on the subject.

This is substantial and follows broadly the same format. There is also a detailed guidance note on domicile and further lengthy explanations of non-resident settlements (as well as the application of s 739 and 740 of the Income and Corporation Taxes Act 1988 (TA 1988) (now s 714 et seq Income Tax Act 2007). To complete the set we have a big document entitled RDRM—the Residence Domicile and Remittances Manual.

I suppose we have been asking for it—if you will pardon the expression. I guess you would call it “quantitative pleasing”. This needs careful analysis and I will return to it in due course.

Attention: Form withdrawal

Immediately before the new guidance was issued, a press release gave details of some other changes on residence and domicile issues. The first of these is that forms DOM1 are being withdrawn. Now

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Quinn Emanuel Urquhart & Sullivan—Andrew Savage

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The government’s plan to introduce a Single Professional Services Supervisor could erode vital legal-sector expertise, warns Mark Evans, president of the Law Society of England and Wales, in NLJ this week
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Professor Graham Zellick KC argues in NLJ this week that, despite Buckingham Palace’s statement stripping Andrew Mountbatten Windsor of his styles, titles and honours, he remains legally a duke
Writing in NLJ this week, Sophie Ashcroft and Miranda Joseph of Stevens & Bolton dissect the Privy Council’s landmark ruling in Jardine Strategic Ltd v Oasis Investments II Master Fund Ltd (No 2), which abolishes the long-standing 'shareholder rule'
In NLJ this week, Sailesh Mehta and Theo Burges of Red Lion Chambers examine the government’s first-ever 'Afghan leak' super-injunction—used to block reporting of data exposing Afghans who aided UK forces and over 100 British officials. Unlike celebrity privacy cases, this injunction centred on national security. Its use, the authors argue, signals the rise of a vast new body of national security law spanning civil, criminal, and media domains
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