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New On The Network Today
This feed is published daily with selected new or updated
content from across our network. For a list of network sites, many of
which feature daily news, see below. |
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| 29/07 New
Lowtax Editor Column, by Kitty Miv |
| 28/07 New
PBTG Editor Column, Caroline, PBTG editor |
| 27/07 UK Launches Raft Of Tax Consultations, Tax-News.com |
| 26/07 Fat
Tax On The Menu
, Jeremy Hetherington-Gore blog entry |
| 23/07 Sarkozy Seeks 'Fiscal Convergence' With Germany, Tax-News.com |
| 20/07 Singapore
Base For Tuvalu OIFC, Tax-News.com |
| 19/07 Expats
Turn Backs On US Taxes, Tax-News.com |
| 16/07
Congress Approves US Financial Reform Bill, Tax-News.com |
| 15/07 New
Lowtax Editor Column, by Kitty Miv |
| 15/07 St
Vincent & The Grenadines, Investors Offshore special feature |
13/07 Tax-News.com
Jersey Review 2010-2011 |
| 12/07 Goodbye
To All That, Jeremy Hetherington-Gore blog entry |
| 09/07
Antigua Pursuing Trade Sanctions Against US, Tax-News.com |
| 08/07 New
Lowtax Editor Column, by Kitty Miv |
06/07 Hong
Kong Full PBTG Guide, added to Personal Business Tax Guide |
| 05/07
Australian Mining Tax Agreement Reached, Tax-News.com |
| 02/07 Online
Trading For Expats, Investors Offshore special feature |
| 29/06 EC
To Extend Common System Of VAT, Tax-News.com |
| 28/06
Lowtax Dubai, annual update |
| 25/06 Jersey
Considers Tax Future, Tax-News.com |
| 22/06 VAT
Hiked In UK Emergency Budget, Tax-News.com |
| 21/06 Steady
Progress In TPP Negotiations, Tax-News.com |
| 18/06 Singapore
- Another Hong Kong?, Investors Offshore special feature |
| 15/06 Swiss
Parliament Approves UBS Agreement, Tax-News.com |
| 14/06 Ethical
Moonshine, Penelope Wise blog entry |
| 11/06 Germany
Purchases Stolen Tax Data Disc, Tax-News.com |
08/06 Dubai
Full PBTG Guide, added to Personal Business Tax Guide |
| 07/06 G-20
Shelves Global Bank Tax, Tax-News.com |
| 04/06
Lowtax Panama, annual update |
| 01/06
Lowtax Luxembourg, annual update |
| 31/05
OECD And EU Strengthen Tax Cooperation, Tax-News.com |
| 28/05
Lowtax Guernsey, annual update |
| 25/05
Lowtax Jersey, annual update |
| 24/05 Lithuania
Summary PBTG Guide, added to Personal Business Tax Guide |
| 21/05
Lowtax Liechtenstein, annual update |
| 18/05 Latvia
Summary PBTG Guide, added to Personal Business Tax Guide |
| 17/05 Offshore
And The Euro, Jeremy Hetherington-Gore blog entry |
| 14/05 IO
Focus: Barbados, Investors Offshore special feature |
03/03
Personal Business
Tax Guide, PBTG, has launched! |
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| Providing essential tax news and information for globally
mobile artists, contractors, entrepreneurs, professionals, small businesses,
sportspersons and entertainers. |
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| Lowtax Network Sites |
| Lowtax Network Portal:
'Low-tax' business and investment in the top 50 jurisdictions covered in
exceptional detail. |
| Tax News: Global
tax news, continuously updated through the day. |
| Investors Offshore:
The independent offshore and alternative investment guide for expatriates
and the globally aware investor. Sponsored by HSBC
Bank International. |
| Law & Tax
News: Daily news and background data on tax and legal developments
for international business. |
| Offshore-e-com:
A topical guide to offshore e-commerce focused on tax and regulation. |
| Lowtax Library:
One of the web's largest and most authoritative business and investment
information sources. |
| US Tax Network:
The resource for free online US taxation information, covering: corporate
tax, individual tax, international tax, expatriates, sales and e-commerce
tax, investment tax. |
| NEW! Personal
Business Tax Guide: Providing essential tax news and information
on business for contractors, entrepreneurs, professionals, small businesses,
artists, sportspersons and entertainers. |
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| Trial Threatens Hands's Guernsey Tax Residence |
by Robert Lee, Tax-News.com, London
Thursday, February 11, 2010
Private equity tycoon, Guy Hands has filed papers with the Southern District Court of New York in an attempt to prevent a court case between his Terra Firma private equity firm and Citigroup being transferred to London, arguing that the move could jeopardize his status as a Guernsey resident for tax purposes.
The case surrounds financial advice provided to Terra Firma by Citigroup in the lead up to the 2007 acquisition of entertainment
group EMI. Hands alleges that Citigroup withheld information pertaining to other
bids, inflating the price paid for EMI to GBP4.2bn, of which GBP2.6bn was
debt, financed by Citigroup. It emerged last week that EMI reported losses of
GBP1.75bn last year, and will likely need to be financially propped up by Terra
Firma.
Despite Citigroup being headquartered in New York - where Hands’s complaint
was filed - the firm has applied for the location of the court case to be changed
to London, where the acquisition was completed – reportedly to mitigate the size of
any potential restitution payment.
Objecting, Hands has stated that holding the court case in the UK would necessitate
him spending significant time in London, which could jeopardize his
tax status, potentially making him liable to UK tax. Should HM Revenue and Customs deem him again tax resident, Hands claims he could be subject
to a claim for personal income tax and capital
gains tax.
In his submission to the court, Hands emphasized that he had not stepped foot in the UK since he announced his move to Guernsey in early-May 2009, and underscored that it was necessary to remain outside the UK for a period of around three years. Hands, who has on occasion spoken out against the UK’s tax system, detailed in the court deposition that despite having his immediate family located in the South of the UK, in Kent, family visits must take place in Guernsey, to avoid the possibility of triggering an HMRC investigation.
UK case law has in recent years seemed to favour HMRC's ever-widening interpretation of UK domicile - notably HMRC v Hankinson, and HMRC v Grace - and British expats now have to ensure that they more or less sever all ties with the UK in order to escape the UK tax net.
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| THE LOWTAX LIBRARY
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