Article
United Kingdom Tax Bulletin (October 2008)
Residence: IR20 Judicial Review
It is well known that Mr Gaines-Cooper is challenging the refusal by HMRC to apply the practice set out in their booklet IR20 on residence. Mr Gaines-Cooper had taken the trouble to make sure that his visits to the United Kingdom were below the 91-day limit contained in IR20 – the terms of which had remained pretty much unchanged for decades – and he therefore considered that he should be regarded as nonresident.
Squire, Sanders & Dempsey L.L.P.