Annual Tax on Enveloped Dwellings and Americans

Some of you will have read about the new Annual Tax on Enveloped Dwellings or ATED on UK residential property held through corporate ownership structures. This applies an annual sliding scale of stamp duty land tax on the ownership of any home over £2m held through a corporate structure as well as tax on certain gains. Many ‘non-doms’ had organised ownership of their home through a corporate structure to provide protection from UK inheritance tax. By shifting the ownership of the UK residential property into a non-UK corporation, the non-dom converted their UK asset into a non-UK asset able to pass outside the scope of UK inheritance tax.

However, if this comes at an annual fee, then this changes the economics of the inheritance tax planning completely. We are advising people to review any corporate ownership for residential property and to consider dismantling the structure. The very recent announcement that George Osborne is considering taxing foreign investors on gains in relation to their UK properties whether or not they are held through structures moves the goal posts still further. We await the 4 December Autumn Statement when we hope there might be clarity…

If you are registered and logged in to the site, click on the link below to read the Withers briefing. If not, please register or sign in with your details below.

Sign in or Register to continue reading this article

Sign in

Register

It's quick, easy and free!

It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.

Register now

Why register to The Lawyer

 

Industry insight

In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.

 

Market intelligence

Identify the major players and business opportunities within a particular region through our series of free, special reports.

 

Email newsletters

Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.

More relevant to you

To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.

Briefings from Withers

  • Family law revolution

    22 April 2014 marked ‘the largest reform of the family justice system any of us have seen or will see in our professional lifetimes’, according to the president of the Family Division.

  • A day out with the Charity Tax Group

    Withers’ Graham Elliott discusses the points he found most interesting from this year’s Charity Tax Group annual meeting.

View more briefings from Withers

Analysis from The Lawyer

Browse This Firm’s

Overview

16 Old Bailey
City of London
London
EC4M 7EG
UK

Turnover (£m): 123.30
No. of lawyers: 313