Non-dom tangle

I have a non-domiciled client who came to live in the UK in 2013 after he retired. The purpose was that this would enable him to see his grandchildren more regularly. Both his daughters are married to UK domiciled husbands.

In 2008 the client purchased a house in London which is owned in four equal shares by our client his wife and the two daughters. The daughters were given cash abroad from an account in Jersey to fund the purchase of their respective shares.

Although the gifts of cash to the daughters are “excluded property” in relation to the client my understanding is that the pre-owned assets tax (POAT) rules will still catch this arrangement.

However I am wondering whether the client could make an election under FA 2004 Sch 15 para 21 and if so what the effect of such an...