HMRC v Embiricos [2020] UKUT 370 (TC) reflects a common issue that arises in connection with tax investigations or audits of internationally mobile individuals. Mr Embiricos  filed his tax returns on the basis that he was resident, but not domiciled in the UK. On that basis, he was entitled to the remittance basis of taxation….

In the 1980s, a new dimension to profit shifting was introduced in the United States through the establishment of Onshore Offshore Banks. New legislation (called the International Banking Facility (IBF)) allowed banks in the US to maintain two separate sets of accounts. One set capturing all transactions with residents of USA which would be subject…