United Kingdom Inheritance Tax Changes - To De-Envelope Or Not?

Summary:

• the United Kingdom ("UK") government has recently confirmed that non-domiciles who hold residential property via an offshore company will be subject to inheritance tax from 6 April 2017;
• we understand that this is the latest in a raft of changes to the UK tax regime of non-domiciles designed to eradicate the previous advantages of owning UK residential property via offshore companies;
• 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 both the British Virgin Islands ("BVI") and the Cayman Islands; and
• given the imminent date of implementation, and the lead time to complete such transactions, we are seeing an increase in the number of properties being de-enveloped by way of voluntary liquidation in both the BVI and the Cayman Islands.