A non-resident non-dom client has been advised by his IFA to transfer a UK-based investment portfolio to a Jersey-based life wrapper for IHT mitigation purposes. The IFA has, however, advised that this will be IHT efficient, even if the underlying investment portfolio within the wrapper is still UK-based. Is that correct?
Boyes Turner LLP
A Jersey-based life assurance contract will be “excluded property”. [IHTA s.6]
The transfer of the portfolio to the life assurance company will be a disposal for CGT purposes.
Any unit trusts or OEICs within the portfolio will already be “excluded property”.
A holding in an authorised unit trust and a share in an open-ended investment company is excluded property if the person beneficially entitled to it is an individual domiciled outside the United Kingdom [IHTA s.6 (1A)]