Jonathan Schwarz's new thirteenth edition of Booth: Residence, Domicile and UK Taxation provides a crisp analysis of this rapidly developing subject, and expertly examines the residence and other fiscal connections for individuals, companies and trusts. The author systematically unravels the tax residence of companies and the resolution of dual residence including specialised residence rules applied to Controlled Foreign Companies, Dual Resident Investing Companies and transfer pricing. The accessible style ensures the reader can quickly grasp the key underlying concepts of residence, ordinary residence and domicile of individuals and fully understand the tests that apply to determine tax liability. All the latest developments are covered, including: Applying the rules in light of HMRC6; Important recent case law: Grace and Genovese, and the Abramovich and Deripaska cases on tax residence; Finance Act 2009 provisions on company residence for the foreign dividend exemption; Corporation Tax Act 2009 references; Residence of trusts: new HMRC guidance; and Changes to HMRC administrative procedures in relation to residence and domicile status.
This popular title will prove an invaluable must read for all accountants, lawyers and advisers to individuals and multinational companies.
Jonathan Schwarz FTII is a Barrister at Temple Tax Chambers and is also a South African and a Canadian lawyer. His practice focuses on international tax planning and tax disputes involving international issues. He has written Schwarz on Tax Treaties, among other publications, and is consultant editor of Annotated Double Tax Treaties. He is a vice-president of the International Fiscal Association and a visiting Professorial Fellow at the School of Tax Law, Queen Mary College, London University. He has been listed as a leading tax Barrister in both the Legal 500 by reference to recommendation for international corporate tax, and Chambers' Guide to the Legal Profession by reference to international transactions and particular expertise in transfer pricing.