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UK resident non-dom HNWI with substantial assets overseas

Question

My client is a UK resident non-domiciled ultra-high net worth individual with substantial assets overseas. He has lived in the UK for many years but under current tax rules he is not yet ‘deemed domiciled’ for inheritance tax purposes. He plans to continue living in the UK and I am concerned about the impact of the ‘non-dom changes’ announced in the 8 July 2015 Budget. One option may be to set up an offshore trust before the client becomes deemed domiciled. Alternatively would a qualifying non-UK pension scheme (or QNUPS) be more suitable for him? Which option would be better for the client and why?
 

Answer

 
The non-dom changes
 
In the Summer Budget technical briefing of 8 July 2015 the government set out in skeleton...
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