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The taxpayer was born in Scotland in 1951. He lived and worked in the UK until 1979 when he took up employment with Shell spending a lot of time overseas.
He kept a house in the UK throughout. In 1997 he was posted back to the UK and in 1998 he left the company.
In 2001 he accepted a three-year contract to work in the USA with effect from 1 July. He was made redundant in October 2002. In December 2002 he leased a property in Monaco.
During 2002/03 he spent 118 days in the UK. In addition he was in the UK for eight days visiting his sick mother and another 14 on her death.
These 22 days did not count under HMRC’s IR20 booklet. In addition he had 54 days of travel of which two...
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