Abolition of the Non-Dom Regime: The State of Tax Planning for U.S. Persons with U.K. Connections

Volume 12 No 6    /    Read Article

By Alexa Collis and Claire Walsh (Guest Authors)

For over 100 years, individuals who were domiciled outside of the U.K. benefitted from the non-dom tax regime. Its features are well known. Individuals who were resident but not domiciled in the U.K. could defer the imposition of U.K. tax on income and gains derived from sources outside U.K. until such time as proceeds were remitted to the U.K. It also meant that only U.K. situs assets of an individual domiciled outside the U.K would be subject to U.K. inheritance tax (“I.H.T.”). Also commonly known is that the non-dom tax regime was abolished earlier this year, being replaced with a new system based on residency. The new system came into effect on April 6, 2025, coinciding with the start of the new fiscal year. In their article, Alexa Collis, a partner of Harbottle & Lewis L.L.P., London, and Claire Walsh, an associate at Harbottle & Lewis L.L.P, London, explain the key features of the new regime. L.T.R.’s, I.H.T., Tails to I.H.T., F.I.G., C.G.T., Tails to C.G.T. and T.R.F. are explained in the context of two case studies. One case study relates to a new arrival and the other relates to a departing person. In this manner, tax buzzwords are placed into real life context. Very helpful.  See more →