Clive Smaldon

Not HMRC...it appears you do not meet any automatic UK or Overseas tests (dont meet automatic UK test 2 if also France home, assume you do have one there also?), therefore you need to look at sufficient ties (insufficent info in your question to determine for sure, however, it looks like you have at least 2 ties (90 day and accomodation) and as spend over 120 days in UK thats enough to make you UK SRT resident. I also suspect you are France SRT resident, spending over 200 days there also, so, you then need to look at the Double Taxation Agreement to determine treaty residence (article 4), as this will then determine where various of sources of income are liable i.e whether solely in the UK ( no Fench Tax Credit), France (no UK tax credit) or whether both countries may tax the source with credit in the other country, but not the excess (you will need to look at each source of income individually in the DTA once you have determined treaty residence)

should have said...If you exited the UK and became non resident by meeting all relevant conditions, any UK immovable property (property, land etc) would remain liable to UK CGT ad infinitum, it is only moveable items (shares etc) that escape and after the temporary non resident period has been exceeded.

Not HMRC https://www.gov.uk/hmrc-internal-manuals/residence-domicile-and-remittance-basis/rdrm11550 As you can see, giving your property to your son does NOT work in terms of then not having an accomodation tie, ownership is immaterial, its "deemed availability"...especially when it comes to connected persons and residence, youd need to not stray over the other conditions attached as detailed on the link avoid it being counted as an accomodation tie.

...not if split year applies from departure (would be curious as to why it doesnt if you moved abroad permanently?)...if claiming split year from Jan 2024 (meaning you dont enter foreign earnings/foreign income etc and dont get taxed on them in UK from leaving) then you need residence pages, so paper or 3rd party software. If not split year then you are liable on worldwide income for the FULL year, even after leaving.

Not HMRC...you can be in receipt of both. You need to speak to NIC office in UK (or check online) to check number of years you have in UK contributions and you can then see how much UK state pension you will get (estimate)...you havent reached UK pension age yet...it will be 66 or 67...rules changed when you were outside of UK...so, the simple answer is you can make your claim re the US social security independently of the UK situation, and inquire of the UK authorities (NIC office) re your record to see if you have a full record, if you need to top up and/or when you can claim the pension from.

should have said...if tax due in the UK calculation is less than paid in Portugal then nothing to pay in the UK, but you cant reclaim any excess. If UK calculation shows more tax due then you pay the difference between that paid in Portugal to HMRC

Not HMRC..on basis you are UK tax resident and not tax resident in Portugal you are liable to UK tax on worldwide income/gains. The Double Taxation Agreement says Portugal can tax the gain, but that it is not only taxable there, therefore it remains liable in the UK also. As you would also be liable in the UK then you would complete a Self Assessment form in the UK, work out the gain on UK rules, and claim the tax paid in Portugal as a Foreign Tax Credit (CGT) against the UK liability so that you get relief in the UK for the tax paid in Portugal. That is the only way it can be dealt with...i.e. dual residence registration is not appropriate for this.

Not HMRC....HMRC periodically run "campaigns" where they ask people to double check certain situations. If your letter says that if youve checked and dont need to pay then you can ignore it, then you can. Sometimes, HMRC include a cohort of people witinin the 10s of thousands they send the letters to who have dealt with it correctly. If you are certain you have dealt with the situation ok then nothing more for you to do.

https://www.gov.uk/tax-sell-home/let-out-part-of-home As you can see, the gain is over the entire period of ownership, the value when you let it out (so the gain when it was your PPR) is not separated...there are various links via that page which explains how its apporitioned

Not HMRC...the £90k is irrelevant. Starting to rent the property is not a trigger date for CGT. When you sell the property the gain is time apportioned over the entire period of ownership, i.e. total gain (including the £90k) x number of months PPR/number of months owned in total is the exempt gain, the balance is chargeable (allowing for 9 months exempt)...it is only the sale proceeds that are relevant on sale, not the value now. The ONLY way for the £90k to escape tax altogether is to sell now or if the market falls from now to sale.