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29 March 2011
A non-dom has set up an offshore trust of which one of the beneficiaries is resident in the UK. Questions include the gift of income from one beneficiary to another and the implications of dividends from a subsidiary company
A non-UK domiciled individual (A) settled an offshore discretionary trust while he was non-UK resident. Initial settled funds comprised of Jersey cash deposits. He was and continues to reside in Dubai. The beneficiaries are his adult children of which two are resident in Dubai and one (B) in the UK. B is claiming non-UK domicile status but not remittance basis. He has now been in the UK for more than ten years.
The trust its immediate holding company and underlying subsidiaries have substantial historic accumulated UK and non-UK source income and gains. They also have income-producing assets that will generate UK and non-UK source income in future. The trustees wish to make a distribution to the UK beneficiary and the following questions have now arisen.
First to avoid an income tax charge...
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