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not remitted to the U.K. resident.61As a result of these rules, individuals who are present

but not domiciled in the United Kingdom pays no U.K. tax on their income that arises

abroad, unless they remit it to the United Kingdom.62

Even further disparagement of the tax code of Britain can be found in the words of

Gordon Brown, Britain’s present Chancellor of the Exchequer (i.e. Treasury Secretary)

who whilst in opposition made the following statement almost three years before

becoming the Chancellor in 1994:

“Taxation of non-residents, non-domiciles and those with offshore accounts

should be overhauled in line with the recommendations of the Inland Revenue

(Commissioners). It is not fair that a wealthy few be allowed to work or live in the

United Kingdom without making a fair contribution through taxation. In Britain it

is easy for a few, even if they live or work here, to avoid substantial amounts of

tax through claiming to be nonresident or non-domiciled and those who are not

domiciled are able to live in the United Kingdom free of tax. In 1988, the Inland

Revenue (Commissioners) recommended a radical new approach to residents and


61 See Langer From 1803 until 1914, U.K. residents were taxable on overseas income only if the income was remitted to the United Kingdom. Since 1914, overseas income has generally been regarded as taxable, except for non- domiciliaries who remain taxable only on a remittance basis.

62 Ibid..He is not taxed on any remittance The U.K. Inland Revenue Commissioners published a green paper in 1998 that proposed significant changes in the way Britain taxes foreign individuals who regularly spend time in the country. If these changes had been adopted, individuals regularly spending an average of more than four months per year in Britain would be taxed on their worldwide income, much as they are in the United States.

63 This quotation was published in Denzil Davies, Booth, Residence and UK taxation (Butterworths, Special Tax Planning, 1997) at section 1.05. It is interesting to note that the section containing this quotation was omitted by the author from the subsequent Fourth Edition of the book, published in 1999.

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