See also:
Pin-pointing Residence – Brass Tax (cadwalader.com)
www.cadwalader.com/brass-tax/index.php?nid=79&eid=338
brodies.com/insights/personal-tax-planning-and-compliance/taxing-individuals-across-borders-how-does-it-work/
Home » Double Tax Treaty » UK: Tribunal confirms Company was also resident in the US for the Purposes of the UK/USA double Tax Treaty