The taxpayer’s wife was an American citizen resident for tax purposes in the United Kingdom. Because of her American citizenship, however, she was not resident in the United Kingdom for the purposes of the Double Taxation Agreement between the United Kingdom and the United States. Her husband was assessed to tax on her American dividends. The assessments were discharged on the ground that the dividends were exempted from United Kingdom tax by the Double Taxation Agreement.
[1972] 1 WLR 1511
England and Wales
Cited by:
Cited – Anson v Revenue and Customs SC 1-Jul-2015
Interpretation of Double Taxation Agreements
This appeal is concerned with the interpretation and application of a double taxation agreement between the United Kingdom and the United States of America. A had been a member of an LLP in Delaware, and he was resident within the UK, but not . .
Lists of cited by and citing cases may be incomplete.
Updated: 26 October 2021; Ref: scu.573171
