Etroy & anr v Speechly Bircham LLP [2023] WTLR 885
Wills & Trusts Law Reports | Autumn 2023 #192The first claimant (the settlor), who was then non-domiciled in the UK, established the Helios April Trust (HAT) in Jersey in 2002. As events then stood, the trust held excluded property for inheritance tax purposes and in which the settlor had an interest in possession. The Finance Act 2006 significantly changed the tax regime for trusts, principally by removing many of the differences between the tax treatment of life interest trusts on the one hand and discretionary trusts on the other. In particular, any additions of UK-situs assets to interest in possession trusts were trea...