Foreign succession law and taxation

By Tolley in association with Richard Frimston at Russell-Cooke Solicitors
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The following Trusts and Inheritance Tax guidance note by Tolley in association with Richard Frimston at Russell-Cooke Solicitors provides comprehensive and up to date tax information covering:

  • Foreign succession law and taxation
  • A range of taxation regimes
  • Conflicts of succession law - examples

A range of taxation regimes

The fact that different states may use common law domicile, deemed domicile, applicable law, civil law domicile, tax residence, habitual residence, nationality or situs of either the donor (or the deceased) on the one hand or the donee (or heir or beneficiary) on the other, means that some assets are not taxed at all, while some assets are taxed twice or multiple times.

For example:

  • The UK taxes UK assets and the worldwide assets of someone dying domiciled or deemed domiciled in the UK
  • Ireland taxes Irish situs assets and the worldwide assets of

More on Cross border estates: