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No certainty when conditions are implied
 
No certainty when conditions are implied
Peter Vaines Partner Squire Sanders & Dempsey
 
When Mr Gaines-Cooper left the UK in 1976 he satisfied the precise requirements of IR20: if you leave the UK permanently or for at least three years you will be treated as not resident providing you do not visit the UK for more than 183 days in any tax year or for an average of 90 days each year.
 
HMRC claimed that there was one term Mr Gaines-Cooper did not satisfy — he did not make a distinct break...

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