Ian Charles Strachan, the appellant, completed his self assessment tax returns for the relevant tax years 2011-12 to 2015-16, on the basis that he was living in Massachusetts, US.

However, HMRC disagreed and issued discovery assessments for the first four of those years, alongside a closure notice and amendment for the fifth year, producing a tax bill for £420,407.29.

This was because HMRC believed that Strachan had a domicile of origin in England, Wales or Scotland. The issue in the case was whether or not this was true, and whether from 1987 to 2006, Strachan was living in Massachusetts.