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My clients are Australian citizens who have been UK resident since October 2013. She was born in Australia and he was born in the UK and they intend to retire overseas within ten years. She has never had UK sourced income or gains.
In May 2017 she sold an Australian residence (property A) with net proceeds equivalent to about £1m. The monies were kept offshore until May 2020 at which time they were remitted. In 2018-19 she sold another offshore property in Australia (property B) this time at a substantial capital loss.
Property A was originally purchased by the husband in April 2002 for around £350 000. The couple who were married at the time lived in the property as their only main residence. In June 2003 the couple left Australia and he rented the property out from July 2003.
In December 2009 the property was...
