Peel the wrapping off an early Christmas present

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Well it is that time of year again and it was tempting to see if I could write a piece that made no reference whatsoever to the festive season! But my plans have been spoiled in the last couple of weeks by an early Christmas present or two.

The first was the court ruling on the issue of residence (and domicile) for Robert Gaines-Cooper and the second was a research paper from the Institute of Public Policy Research. Between them, they have combined to create an environment for sales of offshore investments which will see the UK market continue to enjoy phenomenal growth in 2007. The court case centred on the rules used for determining residence for tax purposes. Mr Gaines-Cooper had been making visits back to the UK on a regular basis, but believed he had kept within the 90 day average of visits over a four-year period. In c...

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