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Repatriation of an off-shore trust

Are there any CGT consequences of repatrioting a pre 1991 offshore trust. The offshore trustees would resign and UK trustees would be appointed. What are the CGT consequences and would any rolled-over gains be crystalised ?
patricia graham

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In reply to Martin's query
Settlor is a beneficiary and the assets consist if land tranferred off-shore because of potential development value. Land would qualify for business asset taper relief and in view of this consideration is being given to the repatriation of the trust due to the amount of fees being charged by the off-shore trustees.

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Could you repost this query with more information?
For example is the settlor a beneficiary, an outline of the trusts investments etc.

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Professional Advice
If I were in your position, I'd seriously consider using a 3rd Party specialist.

Offshore trusts are an area where it is too easy to run into a negligence claim if you don't know what you're doing.

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Foreign Trust becoming UK resident trust

Patricia,

As I understand it your question is about a foreign trust which wants to become a UK resident trust. this being the case, the gain heldover when the trust was first created would not be chargeable until the underlying assets are disposed off. this is the simplest answer you can have because the trust is actually putting itself under the jusrisdiction of UK Revenue Law and so there can't be any penalty for doing so. Unless I have misunderstood your question about a UK trust emigrating then please let me know.

Best regards,

Jay Tanna


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