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What are the tax implications of an offshore trust becoming UK resident?
Our client is a UK resident but non-domiciled individual. He settled funds into a non-resident trust in the late 1990s by which time he was deemed UK domiciled. The amount settled at that time was less than the inheritance tax nil rate band. The settlor and his spouse are excluded from the trust and his children and their issue are the beneficiaries.
The trust owns 100% of the shares in an underlying non-resident company. That company invested in a UK property which has recently been sold and a substantial capital gain has arisen. The non-resident company now has a large cash balance from the sale of the property as its main asset.
In view of the high administrative costs of the trust and non-resident company and to tidy things up consideration is being given to bringing the trust onshore. The plan is to make it a UK...
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
