Residence & domicile

Hansard, 13 January 2011, vol 521, no 98, col 556W

Lyle Grace (TC913)

A US citizen who has lived in the UK for two years is the beneficiary of a US grantor trust and a US non-grantor trust

Legal experts blame annual remittance-basis charge

Removal of warnings of no legal force

Advice is required on whether the £2,000 threshold for the remittance basis for non-domiciles can apply without a formal election

A company is resident in both the UK and in Brazil and wonders whether loss relief will be available as group relief in the UK and by carry forward in Brazil. It seems to be that loss relief can be given in both countries but the operation of double taxation relief will mean that relief is only effectively given once

Is a gain on foreign currency made when funds are transferred abroad for extending and maintaining a property a chargeable gain?

A non-UK income tax domiciled client using the remittance basis for 2008/09 has offshore losses for that year. Can these be carried forward to 2009/10 when the arising basis will apply and there are UK and offshore gains?

A UK-domiciled husband is married to a woman who was born in Denmark and may return there should her husband pre-decease her. The wife’s domicile has never been determined

A client in the emergency services is paid an annual accommodation allowance as he is required to live within 15 minutes of his base. The allowance is paid monthly and is taxed as part of his salary

RORY MULLAN suggests that when moving within the EU, UK nationals resident in this country may be at a disadvantage