The Pre-Budget statement was one of enhanced political significance against the backdrop of a forthcoming General Election. It was widely expected that some measures would be taken against the banking sector. The scale and breadth of ramifications of the bank payroll tax provisions are, however, surprising. There were some significant revenue raising measures which have been highlighted below, together with measures put forward twelve months ago which will have a concertina effect of significantly higher taxes, now for city workers on bonuses and for the higher paid generally from April next year which we remind you of; as well as a surprise national insurance increase across the board.

Raising tax revenues is a high priority for the Chancellor and measures announced in the 2009 Budget and Pre-Budget Report appear to be targeting the highest earners.

Whilst our clients are addressing the implications of recent and prospective new changes to the taxing rules which may fundamentally affect them, it is also important to remember things which haven’t changed, such as the fact that the US continues to impose individual tax on the basis of the calendar year, and the attendant possibility of tax savings through year-end planning. Set out below are some of the planning opportunities that should be considered and where appropriate implemented before the end of 2009. If your particular circumstances suggest other possibilities that you would like to explore, you should discuss them with your advisor at Frank Hirth as soon as possible.

A recent announcement by the IRS regarding modifications to its voluntary disclosure programme may have significant fallout for any taxpayer who has failed to comply with his US tax filing obligations where there is an international dimension. Paul Hocking, of Frank Hirth, comments on the implications.

Mark Walters, senior partner at leading US/UK tax advisory firm Frank Hirth, guides us through the minefield created by the latest budget for UK non-domiciles.

HM Revenue & Customs (“HMRC”) recently announced further details of the second (and expected to be final) opportunity to disclose and pay tax on their non-UK income, the New Disclosure Opportunity (“NDO”).