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Tax-efficient extraction

03 October 2007
Issue: 4128 / Categories: Forum & Feedback

We have a new client who is the settlor of a UK-resident discretionary trust. The principal beneficiaries are his children and grandchildren.The client has a domicile of origin outside the UK, but came to live in England as a child and acquired a domicile of dependency and subsequently a domicile of choice here.

 
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We have a new client who is the settlor of a UK-resident discretionary trust. The principal beneficiaries are his children and grandchildren.
The client has a domicile of origin outside the UK but came to live in England as a child and acquired a domicile of dependency and subsequently a domicile of choice here.

About ten years ago he established a discretionary trust for his family. The client and his wife are excluded from benefiting but they are the two trustees. One of his children has recently emigrated with her husband and their three children. They are living outside of the UK for the long-term and might now have acquired an overseas domicile of choice.

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