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Will a non-resident benefit from his late wife’s inheritance tax nil-rate band?
Our client married a French woman in 1975; since then they have moved between the UK and France. They lived in the UK until 1983 then in France until 1988 and back to the UK until 1990. From 1990 they lived in France until the wife died in 2009. Both husband and wife had dual British and French nationality.
Because they were resident in France when the wife died her estate was taxed under French law. Although my knowledge of French tax law is scanty I understand this involved part of her estate passing to her children under French inheritance laws.
Since his wife died our client has been UK resident although he still owns property in France. He is now contemplating retiring to France and will again become resident there although I believe that he would remain liable to inheritance tax in...
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