New queries, issue 4614

A trust issue

Reporting and tax considerations concerning a US trust of a UK domicile.

A US citizen is deemed UK domiciled after living here for about 18 years. She was the beneficiary of a US trust of which she was the settlor. A few years ago with the sale of US property her wealth significantly increased. Her share of the sale proceeds (US $3m) were retained in the US and invested in a family portfolio worth about US $100m.

We are preparing the UK tax returns and there have been large capital gains in both the US trust and in a partnership which is in essence a pass-through vehicle. I am unable to ascertain the primary taxing rights of the US on these but have noted that tax payments for all of the capital gains have been made to the US. I...