I am dealing with a UK beneficiary of a US estate. As with much US estate planning, the majority of the deceased’s assets are in a revocable trust. The revocable trust states that upon the death of the settlor, the trust property is distributed to the UK beneficiary outright. Will HMRC view this distribution as an inheritance, and therefore it would not be liable to tax, or will it be viewed as trust distribution (and possibly liable to income tax and CGT)?
Thank you.