Winners and losers under the non-dom reforms

Several helpful articles have been published in Tax Journal since the announcements on 6 March 2024 affecting non-doms. The changes are due to come into effect on 6 April 2025. This article assumes that readers are familiar with the main thrust of the Budget proposals and focuses on winners and losers under the regime. Labour announced in April that ‘although they supported most aspects of the proposed replacement to the non-dom rules including the four year window’ they would ‘include all foreign assets held in a trust within UK IHT whenever they were settled so that nobody living here permanently can avoid paying UK IHT on their worldwide estates.’ This ambiguous statement has raised further IHT issues. The IHT implications of the new rules...