TRS - Overseas Trustees

Hi there

Can anyone provide some guidance on the TRS where I have a deceased settlor (Will Trust) and two of the four trustees are US resident.

In particular I’m vaguely aware that there are some workarounds for information requirements where you don’t have NI No or passport details for deceased settlors but I can’t seem to locate that guidance - that which I have found is watermarked draft and I don’t know how reliable it is…

I also wonder if I’m going to encounter any issues with registering the two US resident trustees.


Adam Hills

Hi Adam,

I thought the offer of including passport details was the work around for those individuals who didn’t have a NINO. GOV.UK suggests the following:

If all reasonable steps to obtain the information are unsuccessful (including when a person is deceased) then trustees should use the following information to help identify the settlor or beneficiary.

Date of Birth
If the DOB is not known then enter 01/01/1900.

If the address is not known, we recommend using either the trustees’ or agent’s address, excluding their postcode. The postcode used should be NK1 1NK. This will indicate to HMRC that the address is either not known or no longer exists.

Passport or ID number
If the passport or ID number is not known then use the following information:

Passport or ID card country of issue
Complete this with the most likely relevant country, usually the UK.

Passport or ID card number
Complete this with ‘deceased’ and the year of death, with no spaces. For example, where the settlor died in 1961, you’ll show 31/12/1961.

Passport or ID card expiry date
Complete this with the date of death. If you don’t know the exact date, use 31 December of the year of death, which in this case would be 31/12/1961.

This page also gives options regarding overseas persons.

Lucy Orrow
Lambert Chapman LLP