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Tax cases
The appellant claimed that he left the UK for a year from 6 April 1998 during which time he received a substantial bonus from his UK employer
The appellant was born in Canada but had been resident and ordinarily resident in the UK for many years before 1998-99. He claimed that he left the UK for a year from 6 April 1998 during which time he received a substantial bonus from his UK employer.
From the evidence the Special Commissioner said that this was not a 'distinct break' case in the style of Dave Clark in Reed v Clark [1985] STC 323. This was for several reasons:
- the appellant continued to be employed by the UK employer and did not have full-time employment abroad;
- his work remained the same;
- he did not establish a permanent residence abroad;
- his family remained in the UK;
- he did not open a bank account overseas;
- his centre of vital...
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