Case Studies - International / Offshore - Returning to UK

Mr R had been employed outside UK for many years. His contract of employment was coming to an end and he was planning to return to UK. Mr R’s children were no longer dependent. Mr R’s wife has non-UK domicile status. Although Mr R has been living and working outside UK for many years, he is still regarded by HMRC as UK-domiciled, inferring that his world-wide assets are potentially liable to inheritance tax. Mr R’s estate was valued at $9 million.

Specialist Solutions advised Mr R to re-base his investments, prior to returning to UK, so that inherent gains would be crystallised whilst he was non-resident and also to consider conversion into sterling for some of the investments, to take advantage of currency fluctuations. Specialist Solutions also advised Mr R to restructure his investments in such a way as to make the maximum use of UK tax allowances and to reduce the potential future impact of inheritance tax. For the remainder of the capital, Specialist Solutions advised Mr R on a structure, which defers income and capital gains tax, whilst also allowing tax-efficient distribution of funds. Specialist Solutions assisted Mr R to select fund managers and worked with those fund managers to ensure that the investment strategy is maintained. Specialist Solutions advised on the inheritance tax implications of Mrs N being non-UK domiciled and recommended a course of action to ensure the most advantageous position.