2008 changes

2017 changes

Aircrew

American wives of UK-domiciled taxpayers

Basis of assessment

Beneficiary domiciled outside UK

Capacity to marry

Capital gains tax

Capital gains tax impact

Capital gains tax implications

Categories

Channel Islands, excluded property

Chargeable gains

Children

Abandonment

Generally

Intention

Choice

Choice of

Abandonment

Deceased no intended change of domicile

Failure to establish

Hong Kong, evidence supporting intention

Retention or revival

Settled intention to reside permanently in Monaco

US citizen, inheritance tax charge

Common law concept

Companies

Construction and interpretation of wills

Construction of will

Death outside the UK

Deceased a foreign domiciliary

Deemed

Capital gains tax

Exemptions for foreign trust income

Generally

Income tax

Inheritance tax

Deemed domicile

15 years

2017 provisions

CGT re-basing

Interest-free loans (dangers of)

Settlor-interested trusts

Deemed: income and capital gains tax

Definition

Dependency

Determination

Determination of

Children

Domicile of choice

Domicile of dependence

Domicile of origin

Generally

HMRC guidance

Married women

Mentally incapacitated

Electing for UK domicile

Election to be treated as UK domiciled

Excluded property

Excluded property trusts

Generally

Expats – main effects on

Capital gains tax

Income tax

Inheritance tax

Finance Act 2013 changes

First principles

Fiscal (or deemed)

Foreign income

Formerly domiciled resident

Formerly domiciled residents

Fugitives

Generally

Grant made to person entitled abroad

IHT impact

Implications for residence status of PRs

Income tax

Income tax implications

Individuals must have a domicile

Inheritance tax

Areas of

Choice

Dependence

Determination based on

Electing to be UK domiciled

Excluded property

Fiscal

Generally

Implications

Meaning

Origin

Returns

Spouses and civil partners domiciled overseas

Transfers between spouses

UK situs assets

International wills

Invalids

Isle of Man, excluded property

Legitimacy

Legitimation

Life policies

Linked to system of law

Married women

Meaning

Meaning of UK domicile

Mentally incapacitated persons

Migrant workers

Minors

Minors with foreign domicile

Misdirection

Mixed domicile couples

Non-residents

Non-residents' bank accounts

Not UK domiciled, IHT filing requirement

Of beneficiary

Of choice

Acquiring

Children

Definition

Displacing domicile of origin

Generally

Significance

Of deceased, impact on taxation of foreign income

Of dependence

Child's domicile follows that of parent

Children (illegitimate)

Definition

Generally

Legitimation

Married women

Of origin

Definition

Determination

Displaced not abandoned

Generally

Loss of

Resurrection of (abandonment of domicile of choice)

Resurrection of (inadvertent, moving from state to state)

Of PRs, irrelevant for tax purposes

Offshore trusts

Operation of law

Origin

Overseas electors

Overseas voters

Persons treated as domiciled in UK

Election

Generally

Preliminary hearing to determine appellant's domicile of origin

Prisoners

Probate considerations

Protected foreign source income

Protected settlements

Reform of rules

Refugees

Relevance

Relevance for inheritance tax

Remittance basis

– see also Remittance basis

Generally

Residence

Generally

Members of the House of Commons

Members of the House of Lords

Residence in UK (15 out of last 20 years rule)

Effect on domicile

Inheritance tax

Residence nil rate band

Seafarers

Settled property

Significance

Status, accountant's professional negligence

Statutory residence test

Switching

Testamentary capacity

Trustees

Types of

UK domicile

Effective for tax purposes

IHT filing requirement

Strictly does not exist

UK jurisdictions

UK residence

UK wills

Unapproved share schemes

Validity of wills