Accountancy Age has reported that accountants PKF have warned the draft legislation amending the tax position of non-domiciles will hit all non-domiciled people whether they have been here 60 years or 60 seconds. They said:

[T]he legislation was particularly likely to hit those with investments held in offshore trusts and companies where past income and gains going back for many years might become taxable if brought into the UK after April 5.

Why be surprised? I have little doubt that HMRC wanted to get rid of the domicile rule. The Treasury has not let it do so. It's achieving the aim by all means possible, and rightly too. The abuses they're hitting are real, deliberate and most certainly aggressive with regard to tax avoidance. They should be curtailed.

But it would have been so much better to have abolished domicile altogether.