Barclays Wealth Trustees (Jersey) Ltd & anr v HMRC [2015] EWHC 2878 (Ch)
Wills & Trusts Law Reports | December 2015 #155On 21 June 2001 the settlor, who was then non-domiciled in the UK, settled cash derived from a Jersey bank account on the trusts of a Jersey-resident discretionary trust called the Michael Dreelan Trust (MDT). The settlor became deemed domiciled in the UK for inheritance tax purposes from the beginning of the tax year 2003/04. Subsequently, on 4 April 2008, the settlor and others set up another settlement called the Dreelan Brothers Joint Trust (DBJT) and 25,000 ordinary shares in Qserv Limited were transferred from the MDT. These were later sold for cash that was UK situs property. On 2...