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TAXguide 09/19: Rebasing and adjustment to the CGT foreign capital losses election - professional bodies Q&A

Finance (No 2) Act 2017 introduced significant changes to the taxation of foreign domiciliaries. In TAXguide 09/19 ICAEW, STEP, the CIOT and the Law Society have published questions and draft suggested answers together with comments from HMRC to highlight and consider areas of uncertainty in the statutory provisions for rebasing and the changes to the CGT foreign capital losses election.

TAXguide 09/19

This guidance can be downloaded in full.

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Overview

This guide is one of four outlining questions and draft suggested answers prepared by committee members of ICAEW, STEP CIOT and LSEW to highlight and consider areas of uncertainty in the statutory provisions introduced by Finance Act (No 2) Act 2017 with effect from 6 April 2017. They cover:

  • cleansing of mixed funds (version 3 TAXGuide 02/19 originally published without the HMRC responses as TAXguide 05/18)
  • rebasing and the changes to the CGT foreign capital losses election (this TAXGuide and originally published as TAXguide 06/18)
  • trust protections and other trust issues (TAXGuide 07/18)
  • the extension of IHT to overseas property representing UK property interests (TAXguide 08/19 originally published without the HMRC responses as TAXguide 13/18)

The suggested answers in this updated TAXguide include comments from HMRC.