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Temporary non-residence?

I have a client (UK national & UK domiciled) who left the UK in 2008 for a full-time work contract in the US.

This contract has now ended and I have been looking at how he will be treated on his return within 3 years of departure.  Looking at HMRC6 I have just discovered (in para 5.11) the concept of "temporary non-residence" and the apparent possibility of his being taxed on foreign income such as bank interest which arose while he was non-resident and thus non-taxable in the UK on this.

Does this really mean that, although he will have been treated as NR and NOR throughout the period of his absence (and his UK days have been very few during the period), he could still be taxed on his return to the UK on foreign investment income that arose whilst he was away on some kind of deemed remittance basis?

  

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Remittance or not?

In this situation, income becomes taxable if it was remitted during the period of non-residence, but if there was no actual remittance, there is no liability. Thus if say the foreign bank account is closed and funds transferred to the UK after his return, there is no remittance as he is no longer non-resident at that point.

 

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