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The Chameleon Circuit Tax: Resident non-domicile: Reactions to the proposed changes

03/12/15

We had an excellent turnout last night for our seminar on the Government's proposed changes to the resident non-domiciled regime.

We took a good look at the Government's proposed changes in the light of the consultation paper and the draft legislation issued so far.

The rules are currently in transition on inheritance tax for example as the draft legislation does not take into account representations made to the consultation which closed in November and a response to which will be published by the Treasury early next year.

Nevertheless the direction of travel is clear and we considered the potential impact on a range of typical scenarios including resident non-domiciliaries who will be deemed domiciled for all tax purposes from 6 April 2017, those moving to the UK for the first time and those who wish to leave the UK and become non-resident.  We also looked at trustees of offshore trusts with UK resident beneficiaries and non-domiciliaries and their trustees who hold residential property in the UK through an offshore company.

We are currently advising several individuals who fall into any or more of these categories to consider the potential consequences fully.

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