United Kingdom: Planning For Deemed Domicile With Excluded Property Trusts
With 5 April only a few weeks away, it is time for long-term UK residents to think about whether they are coming up to their deemed domicile date for UK inheritance tax purposes. Those who arrived between 6 April 1998 and 5 April 1999 will become deemed domiciled on 6 April 2014. For US persons facing deemed domicile, there is a planning opportunity with excluded property trusts to preserve the difference between the large US federal estate tax exemption and the relatively small UK nil rate band amount.
It may seem as though the new year has just begun, but time is running out for pre-5 April planning.