UK report illustrates the effect of non-domiciled tax reforms

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The proposals mean that non-domiciles will no longer be able to mitigate UK inheritance tax on residential property in the UK through the use of an overseas company or trust, and permanent non-domiciled status will no longer be allowed for UK tax purposes.

Those who have been UK tax resident for at least 15 of the 20 previous tax years will be deemed to be domiciled in the UK. Any split years of residence will count towards the 15 years after which deemed residency is imposed. However, it remains unclear as to how this rule will be applied where the assets have been purchased originally with untaxed relevant foreign income, cautioned experts.