Thank you for taking the time to go into such detail. I appreciate that - it grounds my thinking, which has been flying all over the place, due to what you correctly describe as badly drafted or imprecise regulations. Even if they were precise - the fact that any IO can interpret-ate any way he/she wants kills any hope. I practiced tax law, including for off shore trusts. There, you could at least tax plan close to the line between avoidance and evasion. but, TIT. The proposal to offer to maintain a 400k deposit for the next 12 months plus 775k of income is an excellent suggestion. I wlll try it out, nothing to lose. If he will not bite, then I will switch to using an agent who is capable of negotiating something better than the status quo.