UK Special Commissioners Decide the Resolute Case Concerning the Taxation of an Ex Gratia Termination Payment as Employment Income

Journal
Cleave, B.
United Kingdom; United States
Bulletin for International Taxation 2011 (Volume 65), No. 1
PriceUSD 45

In this article, the author considers the UK Special Commissioners’ decision in the Resolute case concerning the right to tax an ex gratia payment to a US citizen on ceasing to work in the United Kingdom, which was decided by reference to domestic law and the 2001 United Kingdom–United States tax treaty.