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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...
