There are significant implications for your assets if you live and work in multiple jurisdictions. The issue of your status in International Law is complex, particularly given the concepts of ‘ domicile ’ and ‘ renvoi ’
Recently I have worked on a number of complex cases, which include:
- Finlay: born in Glasgow but worked and died in Ecuador, with substantial assets in England. His son lives in Ecuador, daughter in New York.
- Ivan: born in Paris but “deemed domicile” in UK. Property and assets in multiple global locations.
- Harold: resident in Philadelphia. His father, dies in Nigeria, with houses in London left to his six children.
Add to the above, some of these considerations and the picture becomes decidedly complex in terms of planning:
- UK deemed domicile rules impact on UK inheritance rules
- Changes in income and taxation rules in the UK for non-domiciles
- UK citizens purchasing property abroad and foreign citizens purchasing property here
- Residents in the EU choosing the national law to apply to their wills
- Tax anti avoidance laws
- Forced heirship rules
- Cases where a state imposes taxation on capital gains, even though the gain is exempt in the place of residence.
The question of status for many of us today has far-reaching implications for the value,
management, and taxation of our assets. I would strongly advise getting expert advice when making a Will, applying for probate, and in the general management of your assets.