"Every single penny she earns in the UK she pays UK taxes on... and every penny that she earns internationally, for example in India, she would pay the full taxes on that," he said.
So if the full worldwide tax paid on that Indian dividend in her hands (in an offshore bank account of course) is zero (e.g. no local WHT) with a £30k RBC, that's alright then?
You have to admire their sneaky wording. Apparently they both have Green Cards (which of course helps her assertion that she has not acquired a UK domicile of choice) and so should only be subject to US taxes on US source income (and not large Indian dividends). See:
"9. Tie-Breaker Rule to Apply Treaty Benefits
U.S. green card holders residing in the UK may elect to apply what is known as the tie-breaker rule of the US/UK Tax Treaty and be deemed a resident only of the State (i.e. country) with which their personal and economic relations are closer (UK).
Under such election, the individual would file form 1040NR and report only income derived from U.S. sourced. The requirement to provide full disclosure of foreign bank accounts remains and tax on income from U.S. sources will be higher than tax on the same income when applied to U.S. residents filing form 1040."