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Readers’ forum: Returns for UK trust of non-resident life tenant

24 July 2023
Issue: 4898 / Categories: Forum & Feedback , Residence & domicile , Trusts
Estate with international dimension

Our UK resident clients are the two trustees and also the only beneficiaries of an interest in possession trust set up by their cousin Tony in his will of which his former wife Maria was the life tenant. Tony was UK domiciled and resident and died in 2010. Maria who died last month having permanently left the UK five years ago was non UK domiciled. The affairs of the trust are very straightforward; cash settled into it at the outset of some £900 000 was placed in a deposit account generating modest interest income which was included in Maria’s UK tax returns each year.

The trust ceased on the death of the life tenant and we are instructed to assist the trustees with the trust’s IHT affairs. Importantly however neither ourselves not the trustees are instructed by the overseas...

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