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06 January 2026

Trusts & settlements: gifts with reservation of benefit

In the third part of Emma Chamberlain‘s series for Tax Advisor on IHT, Emma looks a how new residence-based rules mean foreign property can now fall back into charge, fundamentally reshaping the treatment of gifts with reservation of benefit.

You can read a copy of the article here.

The first on whether the new rules are a welcome simplication can be read here and the second article on replacing domicile with long-term residence as the key tax status here.

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