The publication of Spotlight 63 in October [Property business arrangements involving hybrid partnerships (Spotlight 63) – GOV.UK (www.gov.uk)](https://www.gov.uk/guidance/property-business-arrangements-involving-hybrid-partnerships-spotlight-63) and the issue of “nudge letters” this month by HMRC to users of a “hybrid scheme” designed to benefit from lower corporation tax rates and unrestricted interest relief for landlords, looks to be the start of an awakening by HMRC to the abuses of incorporation relief in the property sector.
Non-domiciled tax status, a political hot potato if ever there was one, has been around in one form or another since 1799. Since then, the regime has undergone a plethora of changes...
HMRC won in the recent First Tier Tribunal in the case of Ian Strachan, TC8858. This is a case where the taxpayer argued that he had acquired a domicile of choice in Massachusetts.
