(1). Wren is domiciled in the country of Twitcheria. She came to the UK on 1 January 1994 and has been UK tax resident since that date. In the tax year 2022/23, Wren has overseas income of £3,100, none of which has been remitted to the UK.
Explain whether or not Wren is entitled to claim the remittance basis.
(2). Robin is domiciled in the country of Twitcheria and tax resident in the UK. He is not deemed domiciled in the UK. In the tax year 2022/23 he has overseas income of £38,000 and overseas gains of £1,900, none of which has been remitted to the UK.
Explain Robin’s position in relation to the remittance basis.