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My client emigrated to the US a few years ago and is resident there. He has investment income from the UK mainly dividends of £10 000 and income from a UK resident trust. The income from the trust derives from an interest in possession that consists of property income UK dividends and UK interest.
The trustees have paid tax on their income as follows:
As a non-resident the client’s UK tax liability is limited under ITA 2007 s 811 to the amounts deducted from disregarded income plus the amount of tax for which he would be liable if disregarded income were left out but no entitlement to personal reliefs.
HMRC has looked through the trust income and has taken both the dividends received personally and the dividends and interest received by the trustees as disregarded income. However...
