Application for final or partial closure notice

HMRC enquired into Mrs L’s tax returns for 2014-15 and 2015-16. She had claimed to be subject to the remittance basis on the ground she was not UK domiciled because she was born in the US. She died in August 2018 while the enquiries were still under way.

In January 2019 HMRC concluded the taxpayer had acquired a UK domicile of choice. She had married a British man in 1973 and moved to the UK where she lived for the rest of her life. Further all her social connections were in the UK and there was nothing to show that she intended to return to the US. It issued an information notice (FA 2008 Sch 36).

The taxpayer’s executors asked for a closure notice on the basis the taxpayer was domiciled in the US. She was a US citizen she had family there she used to travel...