Technical Q&As - Finance (No.2) Act 2017: tax changes for non-UK domiciliaries and trusts
The draft guidance has been prepared by the technical committees of STEP, ICAEW, CIOT and the Law Society (Capital Taxes sub-committee) and is designed to assist those advising non-UK domiciled clients on the important tax changes introduced by the Finance (No.2) Act 2017.
The questions and draft suggested answers highlight and consider areas of uncertainty in the statutory provisions for:
The new 11 March 2019 version of the guidance on cleansing of mixed funds (linked above), the new 16 May 2019 version of the guidance on inheritance tax on overseas property representing UK residential property, and the new 29 May 2019 version of the guidance on rebasing and changes to the CGT foreign capital losses election all now include HMRC comments.
Aside from those comments, please note that the draft suggested answers have not been agreed by or commented upon by HMRC at this stage and should not be taken as representing HMRC's views.
The questions and draft suggested answers are intended to assist professional advisers in considering the issues.
They do not constitute legal advice and are not a substitute for professional consideration of the issues by such a professional adviser in each client’s specific context.