Commentary

I5.1317 Beneficiaries of non-resident settlements

IHT, trusts and estates

I5.1317 Beneficiaries of non-resident settlements

I5.1317 Beneficiaries of non-resident settlements

There are two circumstances in which a capital gain realised by trustees of a non-resident settlement can be attributed to, and charged on, a beneficiary who is resident in the UK:

  1.  

    •     where a capital gain realised by the trustees can be matched with a capital payment made by the trustees to the beneficiary (not necessarily in the same year), see I5.1240–I5.1251

  2.  

    •     where the beneficiary receives a transfer of value linked with trustee borrowing (a 'flip-flop' scheme), see I5.1257–I5.1258.

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