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Rebasing and unmixing


Since May 2001 MC has continuously been UK resident although he is not domiciled in the UK (a ‘res/non-dom’). Before arriving in the UK he owned a considerable personal fortune through inheritances and the sale of his adventure travel business in South America. When he settled in the UK MC did not take tax advice other than to rely on the imparted wisdom of his cousin GC. GC had previously settled in the UK and told MC to bring onshore a ‘living fund’ at the outset but to leave the rest offshore. This is what MC did and he has claimed the remittance basis each year since. MC now wants to purchase a country estate in Hampshire but his remaining living fund won’t stretch that far. Can he use the new res/non-dom rules to bring...

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