UK Non-dom Status: An Island Of Territorial Taxation In An Ocean Of Worldwide Taxation

April 11, 2022 - Participants Include:

Jimmy Sexton, Esquire Group - @JimmySextonLLM

John Richardson - @ExpatriationLaw

The recent public disclosure that Rushi Sunack's wife Akshata Murthy  has elected UK "non-dom" status has drawn attention to UK "non-dom" status as a tax planning opportunity.

This is the second podcast where I have explored the entitlement to and workings of non-dom status. Interestingly the claim of entitlement to "non-dom" status appears to be based on the fact that she is NOT a British citizen but a citizen of India. The public outrage seems to be rooted in the observation that "citizenship" is neither relevant not determinative of either citizenship or domicile. If citizenship is not relevant for the purposes of taxation, then one wonders why the United States continues it's citizenship tax regime.

In this discussion, Jimmy and I explore the "inner workings" of the "non-dom" system. We discuss this from both a tax and immigration perspective.

In addition we explore their status as Green Card holders and how this may or may not interact with the claim of UK "non-dom" status.