A FIG from the Ashes – A New Era for International Private Client Tax
A Turning Point for UK Tax
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Jamie Favell
Partner
Jamie is a Chartered Tax Advisor and has worked in private practice for over fifteen years.
Jamie’s client base is comprised of private clients including entrepreneurs’, principals in the financial services industry, property investors, media professionals, professional athletes, actors and musicians.
He has a broad experience of advising private clients, in particular international private clients, in all aspects of their tax and business affairs, including tax planning and mitigation strategies, together with all compliance matters.
Recent advice Jamie has given includes:
- UK Arrival or Exit Planning for private clients moving to/or from the UK,
- Managing the UK tax position for dual residents of the UK and other territories,
- Managing UK tax resident status under the Statutory Residence Test,
- Managing the worldwide withholding tax position for a marquee name sportsman,
- Remittance planning from offshore mixed funds, using the Temporary Repatriation Facility,
- Transition from the non-dom tax regime to the foreign income and gains (FIG) regime for HNW clients,
- Disclosure of offshore income and gains using the worldwide disclosure facility,
- Family Investment Companies : advice, implementation, and ongoing compliance support,
- Inheritance Tax and Succession planning,
- Acting as an expert tax witness in divorce proceedings,
He prides himself on giving his clients first class service and always looks to add value to their situation.
Away from the office Jamie enjoys family life, likes to holiday on the beach or in the mountains as often as possible and is a trustee for his local church.
Testimonials
Blogs I've posted
HMRC Make Gains On Undeclared Capital Gains Tax
It was reported in the press this week that HMRC has increased its activity in investigating underpaid capital gains tax (CGT). The number...
Navigating Tax Residency: Dual Residency, DTAs & Non-Residency Benefits
The Changing World and Tax Residency Challenges
Chancellors last ditch attempt to woo non-doms
In the wake of news that a significant number of non-doms are leaving the UK, a somewhat surprised Chancellor Rachel Reeves has announced...
Tax Case Tests Dual Residency Tie-breaker Tests
We advise a lot of clients on their UK tax resident status and also, in cases where they are dual resident, we assist them in determining...
UK's Wealthy Taking Flight to Save Tax
It is being widely reported in the UK press that UK taxpayers are leaving the UK due to the tax changes coming into force from 6 April...
CIOT Response to Carried Interest Consultation
On 29 July His Majesty’s Treasury (HMT) made a request for stakeholders to provide evidence and comments on proposals to reform the...
Selling goods via online platforms
This article is to make you aware of a new tax alert issued by HMRC which confirms they are targeting those who sell goods and services...
HMRC Target Crypto Gains
If you own any crypto assets, it is important that you consider whether any gains realised have been reported correctly as these are now...
Turning the page to the new Labour government
After 14 years of Conservative rule, Labour has taken the reins under Keir Starmer with a massive majority as the electoral map shifted...
Pandora Papers - Does this affect you?
Last year wrote about offshore income and gains letters being issued to taxpayers who were linked to the Pandora Papers. ...
Selling UK Property While Living Abroad
Our private client Partner Jamie Favell recently caught up with Experts for Expats to discuss the tax issues faced by...
HMRC Success Against Bernie Ecclestone
HMRC Success Against Bernie Ecclestone : What does this mean for those of us that aren't billionaires?Its been widely publicised that HMRC...
HMRC Send 23,936 Offshore Nudge Letters re 2022/23
HMRC continue to become aware of taxpayers who may be in receipt of income/gains from overseas assets via automatic exchange of information...
Post Pandemic Residency Review
It is being widely reported in the press that HMRC are targeting individuals that have claimed non-resident status for UK tax purposes...
7.75% Late Payment Interest - A sting in the tail
[UPDATED TO REFLECT BASE INCREASE ON 3 AUGUST 2023]
Pandora Papers - What were they and what if you were named in them?
The Pandora papers involved the release of millions of documents from a number of different offshore financial service providers, revealing...
Autumn Statement - Summary
Earlier today the current Chancellor announced the latest Autumn Statement. Unlike the “fiscal event” announced 55 days ago by the previous...
HMRC Target Offshore Companies
We have been made aware by the Chartered Institute of Taxation that, the UK tax authorities, HM Revenue and Customs (“HMRC”) intend to...
Mini-budget key points
Today Kwasi Kwarteng presented his first budget and with a clear strategy, reduce taxes to stimulate growth! Some headline changes were...
Non-Domiciled - What is a Non-Dom and what is the Remittance Basis?
There has been a huge amount of press around the fact that Rishi Sunak’s wife, Akshata Murthy, is a “non-dom” and able to access the...
Quid Game - Budget
The 2021 Autumn Budget was delivered today by The Host, the Chancellor of the Exchequer Rishi Sunak.
HMRC Target Crypto Owners
HMRC has warned taxpayers that hold crypto assets, that they should expect to be contacted to verify their tax affairs are in order.As you...
A muted Budget?
The Chancellor’s forthcoming budget is only a few weeks away (27 October) and as usual there is plenty of speculation regarding what...
CGT Hike Looming?
The Sword of Damocles hanging over UK investors is the continued threat of hikes in capital gains tax (“CGT”) rates. The rates of capital...
ATED Filing Obligations and Penalties…
Companies that own UK property are required to file annual ATED Returns (“Annual Tax on Enveloped Dwellings”) with HMRC.
Footballers beware!
Football is currently providing rich pickings for HMRC as illustrated by a recent Freedom of Information request.
Budget 2021
The Budget will be held on Wednesday March 3, 2021.
The UK's Tax return deadline is fast approaching
The UK’s personal tax Self Assessment return deadline is on 31 January 2021. The return covers the period starting on 6 April 2019 and...
Remuneration Trusts Targeted by HMRC
HMRC have published Spotlight 56 entitled Disguised remuneration: tax avoidance by owner managed companies using Remuneration Trusts.
HMRC sets its sights on individuals with overseas assets / income
In recent weeks HMRC have recommenced a campaign which targets taxpayers that have overseas assets, income and gains, which may not have...
Mini-Budget Introduces Immediate Measures to Boost the UK’s “Post-Covid 19 Economy”
The Chancellor has today introduced new financial measures in a mini-budget aimed squarely at creating job placements for the young,...
UK Tax Residency and the Impact of Covid-19
The world is seeing unprecedented disruption as we try and cope with the outbreak of the latest coronavirus.
Budget update 2020-21
Today the UK government announced its Budget for 2020-21.
HMRC’s Offshore Investment Fund Letters
It has become evident that HMRC are acting on information received under the Common Reporting Standards (“CRS”) and other information...
HMRC Requesting Offshore Income & Gains information
As previously discussed here HMRC have been targeting taxpayers who they believe have overseas income and gains, which may not have...
Non-Dom’s Targeted by HMRC Policy Paper
While the 2019 Spring Budget was a fairly benign event for private clients, HMRC published a policy paper which is worthy of further...
HMRC's "Offshore Income or Gains” Letters
HMRC are currently sending out letters to taxpayers requesting more information on overseas income and gains, which may not have previously...
Dual In The Crown: Considering UK and Swiss Dual Resident Status
Our Private Client Tax Partner Jamie Favell was recently featured in the ePrivate Client annual feature on Switzerland discussing the tax...
Mixed Fund Cleansing: Action Required
To recap, if you are a non-dom living in the UK, certain tax residency milestones can impact your tax status. A £30,000 charge applies to...
Who has a requirement to correct?
It has been well publicised by ourselves, the press and HMRC that the ‘requirement to correct tax due on offshore assets’ ("RTC") needs to...
Visa Go Go!
It has been reported in the papers that there has been a sharp rise in applications for the UK’s £2M Tier 1 (Investor) Visa.
EBTs, Contractor Loans and HMRCs Settlement Offer
Freelance workers must declare any tax-avoidance schemes they have used by 30 September or face punitive penalties.
Tax Dual Resident : being tax resident in two places at the same time
It is becoming more and more common for expat workers to commute from their home country to another country where they spend their working...
Non-Dom Tax Planning Update
If you are a non-dom living in the UK, certain tax residency milestones can impact your tax status.
Requirement to Correct : Cleaning up any offshore tax issues
Finance (No. 2) Act 2017 introduced new Requirement to Correct (RTC) legislation which is targeted at non-complicance in respect of...
TAP Advise on Feel Good Group Private Equity Deal
Russ Cahill our Corporate Tax Partner advised on the recent Feel Good Group / Perwyn private equity deal providing providing tax advice to...
Mixed Fund Cleansing
We have assisted several clients with mixed fund cleansing already and now outline here how we have helped one particular client.
Non-Dom Changes and Opportunities
This year’s General Election resulted in a period of uncertainty for non-UK domiciled ("non-dom") taxpayers as anticipated tax laws were...
Cryptocurrency, Bitcoins and Tax
The press often includes articles about cryptocurrency and bitcoin's – perhaps discussing their future, fluctuating values and countless...
Mixed Fund Cleansing and Rebasing for Non-Doms - Effective from 6 April 2017
A written statement from the treasury has today confirmed that new tax laws withdrawn from Finance Bill 2017 will be legislated for in the...
UK - UAE Double Tax Treaty
We have many clients who have moved to the UAE and specifically Dubai in recent years, many of whom are pleased to know that the UK and...
Discrimination Settlements and Tax
You work hard for your employer, however throughout your employment you are discriminated against, due to your age and disability.
D Day is here for non-domiciled taxpayers..
The 2016/17 tax year has ended and the key elements of HMRC's Non-Dom reform are now in force.
Non-Dom Reforms
Many changes to the taxation of Non-Domiciled ("Non-Doms") taxpayers will take effect from 6 April 2017.
ATED - File from 1 April to avoid penalty charges and claim relief...
The annual tax on enveloped dwellings (ATED) has been in place since 2013.
Rebasing and Cleansing Mixed Funds
From 6 April 2017, a non-domiciled individual who has been UK tax resident in at least 15 of the previous 20 UK tax years will be treated...
2017 Year End Tax Tips
With another filing deadline now behind us, it is time to turn our attention to identifying opportunities which can help reduce your tax...
The Art of Tax : Averaging for Creators of Literary or Artistic Works
If you are an author or artists, managing your cash flow and keeping your tax liabilities down is crucial.
TAP Advise on Private Equity Deal
Russ Cahill our Corporate Tax Partner advised on the recent Business Growth Fund (BGF) / Ultra Finishing private equity deal providing...
Non-Dom Reform : Rebasing of Assets
From 6 April 2017 any individual who has been resident in the UK for at least 15 of the past 20 tax years will be deemed UK domiciled for...
Keep FIC in the Family
If you have fully utilised your pension saving allowances, exhausted your trust planning opportunities but still want to be able to plan...
Expat Tax Break : Overseas Workdays Relief
If you are an expat coming to the UK to work there is one UK tax break which should not be ignored...
HMRC's Worldwide Disclosure Facility (WDF)
(Updated 18th June 2019) HMRC are busy collecting data from over 100 countries and their financial institutions on UK resident taxpayers.
