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Newsletter | Articles Home is Where the Heart Is – HMRC Her Majesty’s Revenue and Customs (HMRC) have elaborated on the Gaines-Cooper decision which we reported on in the last edition of the Dossier. The Special Commissioners’ decision in this case appeared to go against the tradition of not counting days of arrival and departure in the maximum 90 days in the UK rule. Now HMRC has declared that the case did not rest on the interpretation of how the 90 days are counted, but was rather a one-off decision resting on the question of whether Robert Gaines-Cooper had ever left the UK. A spokesman for HMRC said, “Where an individual has lived in the UK, the question of whether he has left the UK has to be decided first.” Despite having spent fewer than 90 days in the UK for the last 13 years, Robert maintained homes in both Berkshire and Oxfordshire, where his wife lived, attended Royal Ascot, went shooting and maintained his British citizenship. HMRC said, “He never did wholly reject England, nor indeed, that small part of it located in Berkshire and Oxfordshire, where he had so many ties and connections. On the contrary, he felt its pull upon his affections and interests all his days.” Accordingly, the tribunal decided that Robert was domiciled in England, resident and ordinarily resident for the years concerned. Other “non-resident” millionaires may breathe a little easier for a while longer, provided, of course, that they have severed enough ties with the old country to convince HMRC that they have actually left and their heart has a new home.