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Residence & domicile

R Fryett (TC3360)

The statutory residence test details three instances where an individual will be treated as automatically non-resident. But what is the UK tax liability in respect of earnings received for duties carried out in the UK during the allowed limits for periods spent here?

Tax considerations for US citizens working or residing in the UK

Advisers can be reassured by the Court of Appeal’s judgment in Mehjoo

An Australian citizen is UK resident, but domiciled in Australia. She has inherited a “long-term income stream annuity”, which started in 2002 and will last for 15 years

A non-UK resident lives in Singapore, but owns an investment property in the UK and the rental income profit is subject to UK income tax. He also makes donations to UK charities

A UK-domiciled taxpayer worked in Australia for many years, but has returned to the UK. He has an Australian pension fund, which is not subject to tax in Australia but is in the UK

A US national is the beneficiary of a portfolio of US-based investments and trusts. She is resident in the UK and, for some years, has received US rental income from a property that is now being sold at a substantial capital gain

Metso Paper Bender Forrest Ltd; Metso Paper Bender Machine Services Ltd (TC3056)

  • The New Statutory Residence Test for Individuals: a Practical Guide by Malcolm Finney; £87; paperback; Sweet & Maxwell
  • Residence: The Definition in Practice by Keith Gordon; £48.50; paperback; 137 pages; Claritax Books

A UK businessman lives in the south of France and spends about six weeks working in the UK each year. The company provides accommodation and a car during these visits

J Glyn (TC3029)

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