Readers' forum: Art appreciation

We have been appointed to act on behalf of a client who is a UK resident non-domiciled individual. He became UK resident in 2013-14 and has therefore not become deemed domiciled. He has a substantial art collection some of which is located in his UK residential property and other items are abroad. The art collection had been acquired before our client became a UK resident. It can be assumed that the current market value substantially exceeds the original cost. Our client is considering moving the UK collection overseas and settling it into a non-resident discretionary trust together with the art pieces already located abroad. It is likely that the art pieces will be held by a non-resident company owned by the trust. Thereafter the company may loan him some of the art pieces to be brought to the UK for his enjoyment.

He will remain a beneficiary of the...