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An American citizen began employment with investment bank Goldman Sachs in London in 1994.
He did not expect his employment in the UK to last for more than two years although the period was not stated in his contract and he believed he was a permanent employee in the USA who had been seconded to the UK for a temporary period.
His house in the States remained unoccupied and he signed a two-year lease on a place in London where his family joined him in January 2005.
He left Goldman Sachs in September 2006 and returned to his homeland.
In his UK tax returns he claimed deductions for rent the costs of travel from the London house to his office and for ‘subsistence expenses’ on the basis the office should be treated as a temporary workplace for the purposes of
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