The podcast discusses the abolition of the Remittance Basis for UK Resident Non-Domiciled individuals and explains the new Four Year Foreign Income and Gains regime, after which worldwide income and gains become subject to UK tax. It also considers the new basis for inheritance tax which has changed from a domicile basis to tax to a Long-Term Residence Test, capturing worldwide assets and offshore trust assets within the UK inheritance tax net.  

Also discussed are the changes to Agricultural Relief and Business Property Relief which Caps the combined relief at one million per individual and discuses how this may affect the faring families including future intergenerational gifts.

There is reference to the interplay between the changes and likely impact this will have on international UHNW/HNW families and on factors to consider before April 2025. These include whether to pull the trigger on divorce beforehand in England while there is jurisdiction to do so, and where this may otherwise be lost if not done, and of how to consider any relocation of children because of the split within families who may want to retain educational placements for minors while avoiding the rise in taxes.

Hosted by Family Partner Natasha Slabas and Ingrid McCleave Partner in Private Client and Tax joining as a speaker, to share her insights on the consequences for UK resident Non-Domiciled individuals of the budget changes to the Non Dom rules and the changes to Business Property Relief and Agricultural Property Relief.