Moving from US to UK
Client X was a US resident, US domiciled individual. He established a revocable trust of which he was the sole trustee and transferred all his assets to it. The intention was to provide a vehicle that would not require probate in the event of his death and to enable his assets to be managed in a single efficient vehicle.
Client X subsequently became UK resident and domiciled. Client X retired as trustee in favour of a committee of trustees, one of whom was UK resident and the others were non-UK resident.
We advised client X on a number of issues relating to the status of the trust and whether it was a substantive trust for UK purposes or a bare trust, which was its status in the US. The UK tax consequences were very different depending on the status.