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John was born abroad is UK resident and non-UK domiciled but is deemed domiciled from 6 April 2017. In 1990 he set up an offshore trust which subscribed for the shares in an offshore company. This acquired a UK residential property for £400 000. As principal beneficiary he occupied the property for a few weeks each year and more recently let it.
Returns for the annual tax on enveloped dwellings and non-resident income tax have been filed. The property was valued at £1.2m in 2010 and this value is thought to have applied in 2008 and 2015.
No capital payment payments have yet been made by the trustees. The directors have been offered £1.5m for the property. The company will then be liquidated and the net proceeds distributed to the settlor.
Could readers comment on my analysis?
- The company’s gain (TCGA 1992 s 2B(4)) would...
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