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2009 PBR

  2009 Pre-Budget Report In the end and despite great anticipation the PBR is already known primarily for what it didn’t...
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"Tax Hell"

This article by Nick Morgan, of www.tax-hell.co.uk fame, appeared in the Sunday Times at the beginning of the 2008-09 tax year. We would make the...
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New Disclosure Opportunity (NDO)

Many people are now aware of HMRC’s recently announced ‘New Disclosure Opportunity’ (NDO). Which follows on from HMRC’s...
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Sick Leave and Employees Accrual of Holiday Pay

The House of Lords has ruled in the case of Stringer v HMRC that workers who are refused holiday pay while on sick leave can make a claim to an...
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Private Client Services Print

The Mercury Private Client team advises private clients and their families on all aspects of taxation.  Our advice is aimed at those clients with significant levels of income and/or assets with whom we aim to build a long standing relationship.  We do not compete or conflict with our clients current advisers.

  • In addition to our generic tax knowledge we have particular experience in dealing with farms and landed estates, as well as the capital gains and inheritance tax issues facing high net worth individuals and their families today.
  • We have access to all the other Mercury service streams to ensure that clients receive a joined up approach to their tax advice and have access to all the latest ideas in tax planning. 
  • We provide advice and UK tax return services to those with residence and domicile issues.  In this regard we liaise closely with our Offshore Services group in order to provide the full range of services. 
  • In conjunction with the Mercury Employment Tax group, we provide income tax, capital gain tax and inheritance tax advice to company directors and employees.
  • We offer the full range of tax services, including the preparation of both partnership and personal tax returns, to partnership clients, ranging from established firms, to investment LPs, and LLPs used for a special purpose.
  • We are able to provide advice on US tax issues to the US expatriate community and prepare and file US tax returns.

See Offshore Services

See Transactional Tax Services

See Employment Tax

Case Study

“We met an American Citizen, a long term resident of the City of Westminster.  He has been paying 40% UK tax and 35% USA tax, offsetting his UK against the US tax, as a credit on his annual US federal income tax return.  However, this left a balance of 5% rolling over year after year un-offset on his US tax return.  He could only roll these unused credits forward ten years or back one, but because he had only UK high taxed income there was no opportunity to use up the year by year 5% excess over US taxes.  Over 10 years, he had built up in excess of 500,000 US dollar equivalent.   

By restructuring his worldwide partnership and employment income to actually reflect new opportunities to participate in different roles both in the UK and under separate agreements outside of the UK we were able to provide for income untaxed in the UK.  This income would still be taxable in the USA at 35%, but we were now able to offset the rolled up 10 years worth of tax credits against it.  The income was untaxed in the UK because the individual was not domiciled in England and Wales, claimed the remittance basis and did not remit the offshore income to the UK.  The client was pleased as he was able to receive income effectively tax free, and utilise his rolled up UK tax credits to offset the US tax due on his worldwide income”.  

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