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Question 1a

Your manager has received a letter from Jodie in connection with her proposed emigration from the UK. Extracts from the letter and from an email from your manager are set out below. 
Extract from the letter from Jodie

I was born in 1975 and I have always lived in the UK. I plan to leave the UK and move to the country of Riviera on 5 April 2016. My intention is to move to Riviera permanently and acquire a new home there. However, if my children are not happy there after four years, we will return to the UK.

My husband died three years ago. My brother lives in Riviera and is the only close family I have apart from my children. I will not have any sources of income in the UK after 5 April 2016. I intend to work part-time in Riviera so that I can look after my children. In the tax year 2016/17, I will return to the UK for a holiday and stay with friends for 60 days; for the rest of the tax year I will live in my new home in Riviera.

Extract from an email from your manager

Please prepare paragraphs for inclusion in a letter from me to Jodie addressing the following issues.

(a) UK tax residence status and liability to UK income tax

Assuming Jodie leaves the UK in accordance with her plans, explain how her residence status for the tax year 2016/17 will be determined and conclude on her likely residence status for that year. To help, I have already concluded that Jodie will not be regarded as non-UK resident using the automatic overseas tests so there is no need to consider these tests. 
State how becoming non-UK resident will affect Jodie's liability to UK income tax.

Required: Prepare the paragraphs for inclusion in a letter from your manager to Jodie as requested in the email from your manager. The following marks are available: 
(a) UK tax residence status and liability to UK income tax. (7 marks)

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