Inheritance Tax Manual

IHTM04295 - 바카라 사이트 securities in foreign ownership: ordinary residence

In addition to beneficially owning (IHTM04031) a qualifying FOTRA gilt (IHTM04291), the transferor - or in the case of a qualifying interest in possession (IHTM16062) the beneficiaries concerned - must satisfy the residence conditions under which the security is issued. 바카라 사이트˜Residence바카라 사이트™ and 바카라 사이트˜ordinary residence바카라 사이트™ (IHTM13025) are concepts that are better known in the field of Income Tax than Inheritance Tax.

In some cases, the question of residence or ordinary residence will already have been considered and decided for Income Tax purposes. Schedule IHT401 asks at Question 6 for information about the deceased바카라 사이트™s residency for tax purposes and the taxpayer may support their answer with copies of correspondence with HMRC. HMRC often use abbreviations 바카라 사이트“ 바카라 사이트˜R바카라 사이트™ for resident, 바카라 사이트˜OR바카라 사이트™ for ordinarily resident, 바카라 사이트˜NR바카라 사이트™ for not resident and 바카라 사이트˜NOR바카라 사이트™ for not ordinarily resident.

Refer to Technical any case where you have any doubt or difficulty, or if your decision (whether it is based on the view adopted for Income Tax or not) is disputed by the taxpayer.