Residence & domicile

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 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)

A client worked in Norway between 26 April 2011 and 30 June 2012. Local tax was deducted by the Norwegian associated company. The income has been included on the client’s tax return and double tax relief claimed for the tax deducted

A member of the UK armed forces has been seconded to work in Canada, and his wife is accompanying him. She is working abroad

Tax experts have raised concerns about the government’s plan to impose capital gains tax (CGT) on overseas residents who sell UK property, calling it an attack on rich non-voters and warning that it could discourage foreign investors.

The chancellor, George Osborne, announced the charge in his autumn statement today, after weeks of speculation it would form part of an anti-avoidance package in his speech to the Commons.

S N Rumbelow and P M Rumbelow (TC3022)

An international sportsman owns a retail shop in the UK, but spends only about 100 days in the country each year. He lives with his mother when in the UK. The shop is managed on his behalf, and he has increasing sponsorship income

UK resident clients have sold a property in Florida. Once depreciation has been added back, a capital gains arises in respect of the sale, but unrelieved losses are brought forward from letting the property. US tax law provides that losses from passive income can be seat against a gain on the sale of the asset