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CEO’s conundrum

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12 July 2011
Issue: 4312 / Categories: Forum & Feedback
A UK citizen who relocated to the USA several years ago has recently returned to the UK to work here. His family remain in the USA and he visits them there

My client relocated from the UK to the US several years ago with his family and both he and his wife found local employment in California. They are now in the process of applying for their US citizenship.

My client returned to the UK indefinitely in October 2010 to start work as the CEO of an engineering business leaving behind his family in the US with the intention of returning to the US for holidays whenever possible.

He does not want to relinquish US residency status for fear of this jeopardising his US citizenship application. From a UK tax perspective it seems that split-year treatment will apply for 2010/11 and he will be UK resident from October 2010.

Therefore he will be dual resident in both the US and the UK from October 2010 onwards. Since he returned to...

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