A tax exile is a person who leaves a country to avoid the payment of income tax or other taxes. It is a person who already owes money to the tax authorities or wishes to avoid being liable in the future to taxation at what they consider high tax rates, instead choosing to reside in a foreign country or jurisdiction which has no taxes or lower tax rates. In general, there is no extradition agreement between countries which covers extradition for outstanding tax liabilities. Going into tax exile is a form of tax mitigation or avoidance. A tax exile normally cannot return to their home country without being subject to outstanding tax liabilities, which may prevent them from leaving the country until they have been paid.
Most countries tax individuals who are resident in their jurisdiction. Though residency rules vary, most commonly individuals are resident in a country for taxation purposes if they spend at least six months (or some other period) in any one tax year in the country, and/or have an abiding attachment to the country, such as owning a fixed property.
A very simplified 'rule of thumb' is that under UK law a person is "tax resident" if that person meets any of the residency tests set out under the Statutory Residency Test introduced on 6 April 2014. The reality of the matter is far more complex and unclear.
A permanent resident in the United States is generally treated as a citizen for tax purposes unless his or her residency lapses. An immigrant not legally admitted for permanent residence (such as a guest worker) becomes liable for United States taxes if they spend more than 122 days in the tax year in the United States.
Michael Caine moved to the United States in the late 1970s to avoid the 83% tax on top earners that existed in Britain at the time. He spent several years in the United States before returning to Britain.
Noël Coward left the UK for tax reasons in the 1950s, receiving harsh criticism in the press. He first settled in Bermuda but later bought houses in Jamaica and Switzerland (in the village of Les Avants, near Montreux), which remained his homes for the rest of his life.
Gérard Depardieu, formerly a French national, became a tax exile, taking up an official resident of Néchin, Belgium, on 7 December 2012. Then on 15 December 2012, Depardieu handed back his French passport, and on 3 January 2013, was granted Russian citizenship.
Guy Hamilton, the director of four James Bond films, became a tax exile in the mid-1970s when he was originally hired to direct Superman (1978). Because of the U.K. tax laws, he could remain in the United Kingdom for 30 days a year. As a result, fellow Bond director John Glen has directed five films in the franchise.
The band Jethro Tull moved to France from Britain in 1973, and while there, attempted to produce a new double album, but abandoned the effort.
Tom Jones also moved to Los Angeles for tax purposes following the election of Harold Wilson as British prime minister in 1974, who put income tax up to 83% for top earners.
Roger Moore became a tax exile from the United Kingdom in 1978, originally to Switzerland, and divided his year between his three homes; an apartment in Monte Carlo, Monaco, a chalet in Crans-Montana, Switzerland and a home in the south of France.
In 1978, the members of the band Pink Floyd spent exactly one year outside of the United Kingdom, also for tax reasons.
In early 1970s, some members of The Rolling Stones used trusts and offshore companies to avoid payment of British taxes. According to a 2006 article in the Daily Mail, their holding company was in Holland, where there is no direct tax on royalties, and there were also offices in the Caribbean. The article also says that "they have been tax exiles ever since - meaning they cannot make Britain their main home" and that "The Rolling Stones have paid just 1.6% tax on their earnings of £242 million over the past 20 years." The article also suggests that other performing artists have adopted the same financial arrangements.
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