Increasing Numbers Of "De-Envelopings" Set To Continue

Key Points

• the United Kingdom ("UK") government has confirmed its plans to reintroduce inheritance tax to UK non-domiciles ("non-doms") holding UK residential properties via offshore companies;
• the Finance Bill, which contains the relevant provisions as regards inheritance tax for UK non-doms, is being presented to parliament in autumn and is likely to take effect from 6 April 2017, if passed;
• we are assisting clients 'de-envelope' their UK residential properties (i.e. transferring the property out of the offshore company's ownership) by way of voluntary liquidation in the British Virgin Islands ("BVI"), the Cayman Islands, Jersey and Guernsey;
• we are also assisting with related activity at trust level, particularly in Jersey and Guernsey, whether by way of appointments out to beneficiaries or otherwise; and