IHT on enveloped property: Summer Finance bill

On 13 July 2017, HMRC published some draft legislation for Finance Bill (No.2) 2017 with minor amendments for IHT on enveloped property.

The provisions will be back-dated and apply from 6 April 2017:

UK residential property will no longer cease to be UK situs (for Inheritance Tax (IHT) purposes) by being held in an offshore envelope (e.g. a offshore company).
Loans made to finance the purchase, enhancement or maintenance of such property will also deemed to be situated in the UK so subject to IHT.
Minor interests in UK property will be disregarded, defined as less than 5% of the total interests in the property.

Useful guides:

Non-UK domicile status & tax

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