[IHTM27220] IHTM27220 – Foreign property: property excluded from Inheritance Tax: foreign settled property with non-UK domiciled settlor
IHTA84/S48 (3) and IHTA84/S80 to 82 mean that property situated abroad and held in a settlement is excluded property unless the settlor was domiciled (IHTM13000) in the UK at the time the property became comprised in the settlement.
The position may be different where the gift with reservation rules (IHTM14396) apply.
In the case of property settled by Will, or under the rules of intestacy (IHTM12000), the date of settlement will be the date of the testator's or intestate's death. This does not apply to a reversionary interest in that settled property (IHTM27230).