Alok Guha

Hopefully interesting question regarding remittance into UK while being non resident. Background : Born in India. moved to US for studies and then worked in US many years. No green card. Moved to UK 2001 as expat while on US payroll and got living allowance in UK. Employer hired big-name accountants to fill out my UK and US tax returns. They said I was "non domiciled" and did not have to pay UK tax on US bank interest, dividends etc unless I remitted them to UK which I did not. To be honest expat returns were too complex for me to understand In 2005 I officially relocated to UK on UK pay. From 2005 to 2008, I got US bank interest and dividends of say $15,000. Interest rates were high in those days. I did not know about keeping interest and principal separate, "source ceasing" and other tricks that the wealthy employ. I did not remit any money into UK, so, as a non dom, I was not legally required to pay tax on this $15,000 to UK. In 2008 the non dom rules changed and I started filing tax on arising basis in UK. So any new interest, dividends, capital gains arising in US : I dutifully declared it to UK and paid my tax even if I did not remit to UK. But I did not remit my US funds to UK at all, because if I did that, I would have to pay income tax on the old $15,000 or so. This is not a lot of money but hiring the tax accountant to go thru all the old paperwork may cost a fortune hence I kept putting it off. So, as of now, my investments are scattered between US and UK which is a pain because I have to worry about US funds having HMRC distributor status and various problems. Now I am UK naturalized citizen and resident but due to health reasons I may not be able to reside in UK very long. As per my GP, the cold humid weather triggers my symptoms, so I may have to relocate somewhere warm. But I still want my money invested in UK because of UK laws, protection etc. Once I become non- resident from UK, I will have no ties to UK : No family ties, no property, no employment. I will only have money invested in the likes of Hargreaves Lansdowne, Interactive Investor and my employer pension which will be converted into a SIPP once Ieave my employer. Now the question : After becoming non resident from UK if I then remit all my US funds from US to UK, will be liable to pay UK Income tax on this old $15,000 ? On the rest of the funds, of course UK tax has been paid since I started paying tax on arising basis from 2009. Thank you. AG