Wealth Management Planning addresses the major UK tax issues affecting wealth management planning for both the UK domiciled and non-UK domiciled individual. It explains, with numerous worked practical examples, the principles underpinning the three main taxes: income tax; capital gains tax; and inheritance tax. It is aimed at those involved in providing advice in the field of wealth management planning including solicitors, accountants, financial planners, private bankers, trustees, students of tax and law and the layman seeking in depth knowledge.

The recent Finance Acts 2006 and 2008, in particular, have modified significantly the tax rules in key areas applicable to wealth management planning. These new tax rules are all addressed in detail in this book and include the pre and post Finance Act 2006 inheritance tax treatment of trusts; the new post Finance Act 2008 residence rules; and the new Finance Act 2008 rules applicable to non-domiciled individuals and the tax treatment of off shore trusts.

In view of the increasingly international nature of wealth management planning the book attempts to place the UK tax rules in an international context addressing such issues as: the role of wills in the international arena; the implications of the EU; the suitability of off shore financial centres; and the role and use of double taxation agreements.

Appendices bring together useful material produced by HMRC and a detailed bibliography for the interested reader is also included.

  This book gives comprehensive coverage to the complicated subject of taxation for Financial Planners. It will be very valuable to all those Financial Planners who wish to extend their learning and reference and desire to meet the needs of clients.
NICK CANN, CHIEF EXECUTIVE OF THE INSTITUTE OF FINANCIAL PLANNING.

In this book, Malcolm Finney presents a comprehensive summary of the UK tax rules in straightforward language and with many practical examples. It is a notable achievement to put incomprehensible tax legislation into such readily understandable terms; anyone advising on wealth management will find this to be an invaluable guide to the subject.
MALCOLM GUNN, CONSULTANT, SQUIRE, SANDERS& DEMPSEY

The author demonstrates considerable skill in explaining complicated tax rules in a manner that makes them easy to assimilate and understand. The book contains Chapter summaries, useful Appendices and numerous worked examples, which provide a very clear, helpful explanation of some difficult tax rules. The books contents cover wide areas of the tax system, and yet provide sufficient technical depth to be a valuable point of reference for those involved in wealth management and financial planning.
MARK McLAUGHLIN, MARK McLAUGHLIN ASSOCIATES, MANAGING EDITOR OF TAXATIONWEB

A valuable new text explaining the tax treatment applicable to financial planning products and strategies for UK domiciled persons (UK resident or expats) and non domiciled UK residents. This book will be of interest to a wide readership ranging from students of law and tax, the interested layman seeking in depth knowledge and professionals including solicitors, accountants, financial planners, private bankers and trustees. Malcolm is to be commended on distilling a vast amount of detailed material into a logical and well ordered framework.
ANDREW PENNEY, MANAGING DIRECTOR, ROTHSCHILD TRUST CORPORATION LTD

Malcolm Finneys book is stimulating, innovative and refreshingly practical. Anyone wanting either a high-level understanding of tax principles involved in wealth management or a deeper insight should read this book.
JACOB RIGG, HEAD OF POLICY, SOCIETY OF TRUST AND ESTATE PRACTITIONERS, STEP WORLDWIDE

This book gives comprehensive coverage to the complicated subject of taxation for Financial Planners. Many clients increasingly have diverse and complex needs often spanning different fiscal regimes and to meet their goals and objectives need a greater level of support. This book will be very valuable to all those Financial Planners who wish to extend their learning and reference and desire to meet the needs of such clients.
STEPHER ARTHUR, BARRISTER, LINCOLNS INN

Malcolm Finney, B.Sc. M.Sc. (Bus Admin) M.Sc. (Org Psy) MCMI C Maths MIMA, runs his own tax consultancy and training firm, Pythagoras Training. Malcolms previous experience has included working for the international finance and international tax consultancy J.F. Chown& Company Ltd (now Chown Dewhurst LLP); as partner and head of international tax at the international accountancy firm Grant Thornton LLP; and as head of tax at the London-based law firm Nabarro Nathanson. Malcolm has written extensively on tax matters, has spoken at tax seminars both in the UK and abroad and has been a visiting lecturer at the University of Greenwich Business School.

About the Author xxvii

Preface xxix

Abbreviations xxxiii

PART ONE: THE BUILDING BLOCKS 1

1 Tax Systems and their Bases of Taxation 3

2 UK Taxation: An Overview 11

3 Domicile 21

4 Residence and Ordinary Residence 75

5 Residence, Ordinary Residence and Domicile: Some Practical Points 91

6 Income Source and Asset Situs 99

7 The Principles and Implications of Joint Tenancy and Tenancy in Common Ownership for Spouses and Non-Spouses 111

PART TWO: THE MAJOR TAXES 123

8 Capital Gains Tax 125

9 Inheritance Tax: The Basics 169

10 Inheritance Tax: Exemptions and Reliefs 199

11 Inheritance Tax: Gifts with Reservation 225

12 Inheritance Tax: Excluded Property 233

13 Inheritance Tax Administration 247

PART THREE: TRUSTS 253

14 Trusts: An Overview 255

15 Inheritance Tax: Trusts 261

16 UK Resident Trusts: Income and Capital Gains Taxation 271

17 Non-UK Resident Trusts: Income and Capital Gains Taxation 291

PART FOUR: INVESTMENTS AND PROPERTY 321

18 Investments 323

19 Main Residence or Home 347

20 Non-UK Domiciliaries and UK Homes 367

21 Stamp Duty and Stamp Duty Land Tax 373

PART FIVE: THE INTERNATIONAL DIMENSION 381

22 Non-UK Resident Taxation 383

23 Accessing Offshore Monies: The Non-UK Domiciled Perspective 389

24 The Offshore Dimension 433

25 International Taxation 449

PART SIX: WILLS, PROBATE AND TAX ISSUES 465

26 Wills 467

Appendices 499

Bibliography 539

Index 543