Broome v HMRCC [2011] UKFTT 760 (TC)

Wills & Trusts Law Reports | May 2012 #119

HMRC assessed B as liable to capital gains tax in respect of properties sold in the year ending 5 April 2001 pursuant to s2 of the Taxation of Chargeable Gains Act 1992. B owned three properties in his sole name, two of which were sold in the tax year ending 5 April 2001. B claimed not to be liable as he was not resident in the UK in that tax year. B lived and worked in the UK from 1980. He married in 1989. He became a self-employed consultant in 1995. In 1998 B and his wife separated and by July 1999 they were divorced. B continued to live at the matrimonial home in Hertfordshi...

R (Davies & anr) v HMRC; R (Gaines-Cooper) v HMRC [2011] UKSC 47

Wills & Trusts Law Reports | March 2012 #117

The first appellants were property developers who were resident in the UK until 2001 when, with the benefit of professional advice designed to bring about a cessation of their ordinary residence here, they moved to Belgium to take up employment with a Belgian company of which they had become directors and shareholders. They claimed to rely on the general guidance published by the Revenue entitled ‘Residents and non-residents – Liability to tax in the United Kingdom’, known as IR20. Later that year they realised chargeable gains in respect of which they were liable to capital gains tax un...