Stories have been circulating that the Treasury is considering making changes to the government's proposed abolition of the non-dom regime and in particular the inheritance tax protections currently enjoyed by many non-UK resident trusts: Treasury reconsidering Labour's plan for non-dom tax status - BBC News

This muddies what was already a rather opaque situation and will leave many non-doms, and connected structures, facing difficult decisions.

For example, many trustees of non-UK resident trusts have been considering winding them up ahead of the budget (30 October). The thinking is that distributions from such trusts made now may benefit from current capital gains tax rates whereas distributions made after the budget could be taxed at a higher rate if CGT is raised with immediate effect. 

However, the possible expansion of the temporary repatriation facility to trusts is one reason to consider deferring such moves and these latest rumours about inheritance tax protections also need to be considered.  For many clients, the choice will be between acting quickly (which might offer greater certainty) or waiting (which holds at least a possibility of a more favourable tax outcome but also carries its own risks).

As the non-dom proposals continue to evolve, it is more important than ever to take suitably qualified advice as to their potential impact and what sensible responses might be.