The vote upholding an earlier Court of Appeals decision was a 4 to 1, and came as the Government is preparing to issue, for the first time, a formal definition of what constitutes tax residency in Britain. This ruling is expected to come sometime towards the end of November or early December, according to tax industry sources.
At issue in the Gaines-Cooper case was whether Gaines-Cooper, a wealthy entrepreneur who moved to the Seychelles in 1976, was in fact still technically a UK resident. Although he was careful not to stay 91 days in the UK in any given year, the Court of Appeals ruled in 2010 that his close connections with Britain showed that he was, in fact, still resident, and thus liable for years of back taxes.
