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Overseas gains

17 March 2015
Issue: 4493 / Categories: Forum & Feedback , International , Investments , Residence & domicile

Minimising the UK tax liabilities on investments held abroad

Our client is a US citizen and is domiciled in the US. However she has lived in the UK since 2000. Because a property has been sold in the US my client’s cash reserves have been increased substantially. The proceeds are retained in the US in a bare trust in her name and will be invested in various funds and sub-funds.

The client is buying a property in Ireland and it is possible that one of the UK Ireland or the US will be her permanent base in the future.

In 2017 our client will be deemed UK domiciled for inheritance tax purposes if she remains in the UK. We would appreciate readers’ advice of the following subjects.

  • The US Irish and UK inheritance tax implications assuming a wealth of $10m.
  • For UK and Irish tax purposes ...

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