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MALCOLM FINNEY explains that excluded property is not always as excluded as one might think
KEY POINTS
- The relevant property regime and excluded property.
- The use of excluded property trusts.
- Five ‘traps’ are explored.
- The effects of acquiring a deemed domicile.
- Transfers between domiciled and non-domiciled spouses.
The inheritance tax treatment of trusts was radically changed by FA 2006 and two years later FA 2008 changed probably forever the income and capital gains tax treatment of the non-UK domiciled but UK resident individual.
However no part of FA 2006 or FA 2008 directly changed the inheritance tax treatment of excluded property or the so-called ‘excluded property trust’.
This article looks at excluded property and the ‘excluded property trust’ and highlights where traps for the unwary can still arise. It includes problems which arise indirectly from the FA 2006 changes (see ‘Trap 1’ below).
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