RDRM24030 - Domicile: Illustrative Scenarios: Mrs E
From 6 April 2025, the concept of domicile as a relevant connecting factor in the tax system has been replaced by a system based on tax residence. This guidance remains for reference purposes only.
E is a US citizen with a domicile of origin in Texas who married, in July 1972, a man domiciled in Scotland. E has lived since then in Scotland, although she has a holiday home in Florida, bought in 1977, where she has spent several months a year following her husband바카라 사이트™s retirement in 1998.
E바카라 사이트™s husband is eleven years older than she is and has recently been in poor health. E has always wished to return to the USA, but her husband will not contemplate leaving Scotland permanently. E would be happy to live out her days in Florida.
The couple바카라 사이트™s only daughter emigrated to British Columbia during 2004. At common law E바카라 사이트™s domicile is Scotland, as she has not taken the steps necessary to lose the domicile of choice there imposed upon her by section 4 of the DMPA 1973. When applying the UK/USA Double Taxation Convention (DTC), E바카라 사이트™s marriage is deemed to have taken place on 1 January 1974. In the absence of an intention on her part at any time to remain in Scotland indefinitely, E바카라 사이트™s domicile of origin in Texas will still be operative for the purposes of the DTC.
Refer to RDRM22240 and RDRM22250.
Note: this example illustrates the position prior to the introduction of deemed domicile from 6 April 2017.