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New queries, issue 4635

13 February 2018
Issue: 4635 / Categories: Forum & Feedback

Long forgotten; American issue; Red light; How the land lies

Long forgotten?

Tax liability of a UK trust set up for benefit of UK residents and non-doms.

I have been asked to take over the tax returns for a trust established in 1966 when a UK resident died intestate. The beneficiaries are entitled to a share of the estate based on the rules of intestacy. The trustees are and always have been UK resident.

The property in the trust is a piece of land in the UK and the income consists of rent from this. Six of the nine beneficiaries are non-UK residents. The person who dealt originally with the tax affairs was the solicitor acting for the trust. He has since died but he appears to have registered the overseas beneficiaries for the non-resident landlords scheme (NRLS).

However all that has been submitted to HMRC under the NRLS is an annual information return which is for...

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