When the non-dom charge was introduced in 2008, the Budget papers contained a lengthy opinion obtained by HMRC from Skadden, Arps, Slate, Meagher and Flom LLP, the distinguished US firm, to the effect that credit would be available for the £30,000 charge against the individual’s liability to US tax.
HMRC also published some proposals for the taxation of foreign domiciled individuals broadly following the announcements made in the Budget.
The Transfers of Assets Abroad legislation in and around section 720 Income Tax Act 2007 (probably still better known under its previous incarnation as Section 739 TA 1988) is exceptionally complex, being designed to frustrate plans to avoid income tax by arranging for income to be paid abroad.
Following Malcolm Gunn's detailed explanation of the draft legislation on disguised remuneration in the December Bulletin, HMRC have published a list of 33 frequently asked questions on the subject.
Many people are steeling themselves for the payment of the £30,000 non-dom charge on 31 January so that they can continue to benefit from the remittance basis.
Some uncertainty has arisen recently about the corporation tax treatment of distributions.
The note prepared on the afternoon of Budget Day contained the main areas likely to be of interest.
HMRC have published some guidance regarding the forestalling provisions relating to the new pensions regime whereby tax relief for pensions is reduced for those earning more than £150,000.
It may be remembered that Mr Darling proposed in his Budget that the senior accounting officer of a company would be obliged to ensure that the accounting systems are adequate for the company to make accurate tax returns.