DOMICILE

Consultant Jihao Zhang works through eight scenarios for offshore trusts under the new long-term residence test, covering living and deceased settlors, the IHT tail, transitional protections and the £5m cap.

Emily Osborne

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Peter Vaines

Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...

Judicial review concerning legitimate expectation over domicile status

Foreign property added to excluded property settlement when deemed domiciled is not relevant property

Determining domicile: In A Weis v HMRC [2025] UKFTT 348 (TC) (21 March), the taxpayer, a Rabbi, had been born in the UK in 1949 in Manchester to a father who had been born in Eastern Europe but had come to the UK in 1938. The father had acquired...

Emma Chamberlain

Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.

Dominic Lawrance

Sophie Dworetzsky

Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) share their views on the current tax regime for UK resident non-domiciled individuals and what might happen under a Labour government.

Claire Weeks

Clare Maurice

Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why returning to the UK after a period of non-tax residence is not for the faint hearted.

Hugh Gunson

Louise Paterson

With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.

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