Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

Readers’ forum: Issues replacing trustees

13 November 2023
Issue: 4913 / Categories: Forum & Feedback , Residence & domicile
Bringing trusts onshore

A who was domiciled and resident in South America settled funds in 1990 on discretionary trusts appointing Guernsey resident trustees. There is also a UK professional protector. A has since died. The primary beneficiary is A’s daughter B who has been settled in the UK for the last 40 years or so and is now deemed UK domiciled.

The trust’s assets now comprise cash of £200 000 in an overseas bank account and shares in a Moroccan company whose sole asset is a residential property in that country. The property is not let but under a licence B and her family or friends occupy it occasionally. Any deficiency of licence fee income over running expenses is made good by B. The property is now probably worth more than its book cost. The aim is to sell the property and wind up the trust. This...

If you or your firm subscribes to, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or '' for further assistance.

back to top icon