Ireland 
USA Domicile: where are we now?
On 6th March 2024, the Conservative Chancellor of the Exchequer announced his intention to remove the longstanding concept of domicile from the UK’s tax code. In July, the incoming Labour Government confirmed their intention to carry through the Conservative proposals with effect from 6th April 2025. They did not confirm the detail of their thinking. Would they honour some of the suggested transitional provisions, or would they go further with even more radical proposals?
In this recording we survey the landscape today.
During the recording, we will:
- Provide a summary of what we currently know
- Explore the implications for people in various circumstances
- Discuss possible planning strategies between now and 5th April 2025, for individuals, families and trustees
- Outline post-2025 scenarios and options
Speakers
Anita Millar-Neale
Personal tax
Anita joined Evelyn Partners (formerly Smith and Williamson) as a Partner in May 2017 following 16 years at another leading Private Client Firm. Before that, she worked at a Private Bank, having trained within the Big Four. Anita has over 25 years’ tax experience, over 20 of which have been in the Private Client sector.
Anita has a varied client base made up of international families, non-domiciled individuals, clients with residency issues, trusts, UK based high net-worth individuals and executives. Anita assists clients with their tax compliance, HMRC investigations and to fulfill their regulatory obligations as well as advising on strategic tax matters such as domicile, residence, family wealth, trusts and succession.
Angela Hughes
Personal tax
Angela looks after both UK-based and international individuals and families, along with their trusts and wider financial concerns. She is a regular contributor to public consultations on proposed tax legislation, as well as to Evelyn Partners tax publications. Angela takes a keen interest in the tax issues (often cross-border) facing the world of classical music, and advises agents, orchestras, singers and instrumentalists.
Joe Johnson
Personal tax
Joe has over ten years of experience in advising international private clients and has helped some notable individuals and families navigate recent headline tax changes in the UK. This includes the changes to the taxation of non-UK domiciled individuals and non-resident trusts from April 2017 and the reform to the taxation of carried interest and returns from private equity funds from 2015 onwards.
He has advised a number of senior private equity executives, both whilst they remained affiliated with a particular house but also their own private offices following their retirement.
Oliver Morgan-Crosby
Personal tax
Oliver advises internationally focused ultra-high net worth individuals, families and family offices as well their structures. He advises on a wide range of private client, private company and trust tax and governance issues. Oliver’s current work includes tax multidisciplinary and multi-jurisdictional project management; advice to internationally mobile family offices including tax pre-immigration/emigration planning; funding UK expenditure; structuring for the acquisition, build and maintenance of luxury assets; advice on business interest structures; and advice relating to tax investigations.
