By James Kessler published by Key Haven Publications PLC

ISBN 1 901614 15 8, price £125 (Hardback p.494).

Everyone knows that tax is complicated; many think needlessly so. Authors have responded to this in discrete ways. On the one hand there is the encyclopaedic approach like Simon's Taxes, so large that it is necessarily the work of many individuals. On the other hand are monographs which aim to deal only with one subject. Each has its place. But the justification for the latter must lie in its elucidating the chosen subject in a manner not achieved (and probably not achievable) by the encyclopaedias. This the author achieves with Taxation of Foreign Domiciliaries, which has grown out of the third edition of his Tax Planning for the Foreign Domiciliary. This subject has more comfortable boundaries than formerly.

As such the author has been able to impose a very clear structure on the work making its contents readily accessible. What is desirable in a monograph is that within its compass it is exhaustive. In the main the author achieves this by dealing with the relevant points in sufficient detail to enable the reader to find the answer to his or her problem. But there are exceptions as for example s.68(4) of ICTA 1988 which the author expressly does not treat, it being "too specialist". This is disappointing, but perhaps merely illustrates that sometimes a logical stopping place has to give way to a pragmatic stopping place. And at least the author does flag up the problem so that the reader is not misled.

Sometimes, as with issues of the correct test to apply to determine whether a taxpayer is resident, the Revenue approach is difficult to contest because the case law is so vague. Here the Revenue's precise words, whether in their Manuals, concessions or elsewhere, are important: it is a welcome feature of Taxation of Foreign Domiciliaries that they are to be found within it, woven into the author's commentary. However the thrust of the book is still towards tax avoidance/mitigation. Where appropriate, given the difficulty of challenging the Revenue interpretation, the author indicates practical steps which may be taken in order to produce the result desired by the taxpayer whilst not mounting such a challenge.

There are some minor typographical blemishes. However, against these infelicities, one may place the huge benefit which flows from the author's willingness and ability to break down complex legislation into its component parts, adding emphasis and paragraphing to ease the reader's task. His scholarly treatment of the transfer of assets provisions contained in ss.739 and 740 of ICTA 1988 illustrates this well, but it pervades the whole book. The book also, and most usefully, contains worked examples to assist in fully understanding the more complex areas. It is written in a most readable and lucid style (although the sentence on p.304 "Every out of trust administration is potentially relevant is an honorable exception), which, taken with the plentiful headings and sub-headings makes the book extremely user-friendly. It also enables the book to be read profitably in short bursts since it is very easy to pick up where one left off; this is especially welcome in that it enables the reader to understand fully part of a topic, leaving the balance to another occasion, or when tackling the more recondite areas, which benefit from reading several times.

Furthermore, although the book is not now 'merely' limited to tax planning the author takes pains to summarise tax strategies: these are both beneficial in themselves and provide helpful aides-memoire (see for examples taken at random, paragraphs 10.15 and 13.12 - 13.15).

Overall there is much of genuine interest in this book. Although the author's aim is to expound fully the tax treatment of foreign domiciliaries, the nature of the subject is such that there is much of relevance to the UK domiciled taxpayer. There are many analyses which, whilst squarely central to the book's purpose, have relevance beyond that. It is accessible to the reader with no specialist taxation knowledge, and contains examples and clear statements so that such a person could deal confidently with the simpler issues without further specialist assistance.