7033CLS - International Taxation Law - Legal Advice - Mick Swagger Musician - Law Assignment Help

Assignment Task

Assessment Information
This assignment is an individual assignment.

This assignment requires you to answer the following question:
Mick Swagger is an international rock and blues musician. He is a dual British and German national as his mother was English and his father was German. Swagger spent most of his life living in the UK, however, in recent years he spends much of his time in his home in Bridgetown, Barbados. Swagger usually arrives in Bridgetown in early November and leaves again in late February. Swagger usually then returns to his home in Essex, England, for two-and-a-half months, spends the summer on tour with his band, the Strolling Bones, and spends September and October with his family in Los Angeles.
In April 2019 Swagger was employed by the BBC in London to present ‘The Blues Show’ on BBC Radio 2. His contract of employment is governed by English law, but Swagger presents the show remotely depending upon where he is in the world. As Swagger is usually on tour in the summer, he pre-records most of the programmes from his home in Barbados. Swagger spends the summer of 2019 on tour, and then in August 2019 the Strolling Bones take up a three-month residency at the Britannia Hotel and Casino in Las Vegas, playing five concerts per week.
Along with his bandmates, Swagger owns a 25% share of Bonegear Ltd, the company that sells Strolling Bones merchandise while the band is on tour. Bonegear Ltd is a company registered in the United Kingdom, although its board of directors typically meets at Swagger’s home in Barbados. During the band’s stint at the Britannia Hotel, Bonegear sells merchandise through a temporary stand in the lobby of the Hotel’s concert arena.

In February 2021, Swagger receives a tax assessment from the Barbados Revenue Authority with a demand for income tax payment on:
• Swagger’s earnings from his BBC Radio programme;
• His income from touring with the Strolling Bones, including his residency in Las Vegas;
• His investment income from Bonegear Ltd.

At the same time, Bonegear Ltd, which usually accounts for its profits with Her Majesty’s Revenue and Customs, receives an assessment for corporation tax payable on its Las Vegas profits, from the US’ Inland Revenue Service as well as the Barbados Revenue Authority. Advise Swagger as to his tax liabilities with respect to the revenue authorities of Barbados, the United Kingdom, and the United States.

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