Commentary

I12.903 Foreign domiciled settlors

IHT, trusts and estates

I12.903 Foreign domiciled settlors

I12.903 Foreign domiciled settlors

Where someone with substantial assets has a foreign domicile but may soon acquire a UK domicile, or may soon become deemed UK domiciled, there is a clear IHT advantage in his settling some of those assets before he acquires a UK domicile, so that so long as the settlement consists of assets situated outside the UK the settled property will be excluded property.

If the settlor wishes to improve to does not wish to divest himself entirely of the economic enjoyment of the settled assets he should consider making a settlement under in which he retains an interest, with suitable remainders over. The reservation of benefit rules are now accepted by HMRC as not being applicable in relation to excluded property. There was, however, a

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