In The Executors of Mrs R W Levy v HMRC [2019] UKFTT 418 (26 June 2019) the FTT refused to direct HMRC to issue closure notices.
HMRC had opened enquiries into Mrs Levy’s returns for the tax years 2014/15 and 2015/16. She had claimed in those returns to be subject to the remittance basis on the ground that she was not domiciled in the UK. She died in August 2018 when the enquiries were still open.
Following extensive correspondence HMRC had issued its decision that Mrs Levy (who was born in the USA) had been domiciled in the UK as she had acquired a domicile of choice. Her executors still maintained their application for a closure notice and resisted the provision of information concerning income or gains arising outside the UK on the ground that Mrs Levy had in their view been domiciled in the US in...
