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27 January 2025
Irish resident
An individual (known as Mr X) who was domiciled in the UK but lived in Ireland was the appointed beneficiary of an offshore trust. He was appointed the main beneficiary in the 1990s on the death of the appointor.
- The trust was settled by a UK domiciled settlor.
- Mr X had a qualifying life interest.
- The qualifying life interest was terminated but the life tenant continued to benefit. So Mr X reserved a benefit under gift with reservation (GWR) rules.
- Mr X died resident in Ireland leaving no assets in the UK at all. As a result no executors have been appointed for a UK probate hence no IHT400 forms will be submitted ie no IHT reporting by executors for the GWR. His executors in Ireland do not deal with the UK IHT reporting. There does not seem an appropriate IHT100 form for...
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