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The taxpayer completed his self-assessment tax returns for the tax years 2011-12 to 2015-16 on the basis that he was domiciled in Massachusetts.
HMRC disagreed and issued discovery assessments for the first four of those years and an amendment for the fifth year.
The issues were whether the taxpayer had a domicile of origin in England and Wales or in Scotland; whether from 1987 to 2006 he had a domicile of choice in Connecticut; and whether from 2006 he had a domicile of choice in Massachusetts and if not whether he had been careless when he completed his 2011-12 and 2012-13 tax returns.
The First-tier Tribunal decided that the taxpayer’s domicile of origin was England. His father was born in Scotland but he moved to England when he was age 21 having qualified as a doctor. He did not retain a property in Scotland....
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