Question 4b i
(b) Buraco’s links with the country of Canasta:
– Buraco is domiciled in Canasta.
– Buraco owns a home in the country of Canasta.
– Buraco’s only income is in respect of investment properties in Canasta.
– Buraco frequently buys and sells properties in Canasta.
Buraco’s links with the UK:
– Buraco’s ex-wife and their 12-year-old daughter moved to the UK on 1 May 2013.
– Buraco first visited the UK in the tax year 2013/14 but was not UK resident in that year.
– Buraco did not own a house in the UK until he purchased one on 6 April 2014.
– Buraco expects to live in the UK house for between 100 and 150 days in the tax year 2014/15.
Required:
(i) Explain why Buraco will not satisfy any of the automatic overseas residence tests for the tax year 2014/15, and, on the assumption that he does not satisfy any of the automatic UK residence tests, explain how his residence status will be determined for that tax year. (7 marks)