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Change from Non-UK domiciled to UK domiciled

Irish nationality client wishes to become UK domiciled

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Client born and grew up in USA, has Irish passport by virtue of parents, been living and working in UK for 13 years and until now has operated as non-UK domiciled.  Minimal overseas income and certainly below £2,000.  Minimal estate value and no prospect of it becoming larger in foreseeable future.  Foreign income may increase to greater than £2k but not by much and client is considering becoming UK domiciled.  Is it a simple case of no longer submitting the SA109 section and continuing as a UK domiciled person or is there a procedure to follow?

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By David Treitel
16th Dec 2019 10:13

As the client is a US citizen and the United States charges tax on worldwide income and gains it would unusual that electing to claim the remittance basis would have saved any tax globally. Has the client been filing US income tax returns each year?

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