Income tax – Residence. The Upper Tribunal (Tax and Chancery Chamber) (the tribunal) allowed the appeal by the Revenue and Customs Commissioners against a decision of the First-tier Tribunal (Tax Chamber) (the FTT) that the taxpayer had not been resident in the United Kingdom for the tax year 2006/2006 and was therefore not liable to income tax of £5.5m on a dividend of some £24.59m paid to him in that year. The tribunal decided that the FTT had taken into account irrelevant factors and had failed to have regard, or sufficient regard, to certain relevant factors.