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17/08/2009
UK tax residence is crucial in determining a client’s liability to UK taxation. Although UK tax legislation also looks at domicile and location of assets, residence is the primary basis for many UK taxes. There is however no statutory definition of residence.
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Should a lay trustee whose co-trustee was the Executor and Trust Company of a solicitor’s firm be entitled to argue that he had a reasonable excuse for the late payment of capital gains tax (CGT) on a share sale because HMRC had not drawn the payment on account feature to his attention?
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