The First-tier Tax Tribunal's (FTT’s) decision in the Perlman v HMRC domicile dispute case (2021 UKFTT 219 TC) appears to confirm that HMRC can demand information about a taxpayer's unremitted foreign income and gains, even if it has not been established that the taxpayer was UK-domiciled for the relevant tax years. Earlier rulings in similar disputes have produced contradictory decisions, with the arguments turning on whether the information demanded is 'reasonably required' by HMRC. Advisors are now awaiting the England and Wales Court of Appeal's decision on the related Embiricos case, due to be heard in February 2022...