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Issue:
4184
/
Categories:
Comment & Analysis
, Abramovich
, Grace
, Income Tax
, Residence & domicile
MIKE TRUMAN and CHARLENE CHOI listened to the arguments in court as HMRC appealed the taxpayer's win in Grace
KEY POINTS
- High Court appeal heard judgment reserved.
- Arguments about temporary purpose permanent residence and distinct break.
- Relevance of recent Abramovich case.
- Difficulty of overturning Commissioner's decision.
The last of the three residence cases heard in recent years by the Special Commissioners the only one where the taxpayer represented himself and the only one where the taxpayer won was Grace.
The decision of the Special Commissioner Dr Nuala Brice was given in January this year. On 4 November the High Court appeal was heard before Mr Justice Lewison who also heard the appeal in Shepherd.
Ingrid Simler QC appeared for HMRC as she did before the Special Commissioners and Keith Gordon appeared for Mr Grace. Judgment in the case will be given on 11 November after this issue...
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