The Government has proposed a period of 24 months to 5th April 2019 to enable individuals who become UK deemed-domiciled to separate out clean capital from accounts holding mixed funds (i.e. capital mixed with income and gains).

The opportunity is only available in respect of cash held in overseas banks (i.e. not property) and, in order to be effective, will, in many circumstances, mean a substantial amount of work and analysis to sufficiently prove that what has been distilled from a mixed fund is indeed clean capital so that this evidence can be provided to HMRC to receive return of capital treatment.

Note that this opportunity is available to a wider class of taxpayers than the capital gains rebasing opportunity – it is also available to all UK deemed-doms in that it is available to any taxpayer who has paid any tax on the remittance basis (and not just those who have paid the remittance basis charge).

Bourse 2017 Nom-Dom Solution

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