Commentary

I12.308 Non-UK domiciled settlors and foreign property

IHT, trusts and estates

I12.308 Non-UK domiciled settlors and foreign property

I12.308 Non-UK domiciled settlors and foreign property

A key issue in the context of foreign property relates to the situation where a non-UK domiciled individual establishes a discretionary settlement of excluded property under which he is a beneficiary. If by the time of his death the settlor has acquired a UK domicile (either under the general law or by operation of the IHT deemed domicile provision)1, will the reservation of benefit rules apply with the result that the trust fund is included in the settlor's estate' HMRC now accept that provided the settlor was domiciled outside the UK at the

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