Excluded property for Inheritance Tax purposes

Barclays Wealth Trustees (Jersey) Limited & Michael Dreelan v HMRC [2017] EWCA Civ 1512

A non-domiciled settlor settled excluded property on the terms of a settlement falling within the relevant property regime. That property was subsequently transferred to a second settlement by the same settlor, who by that time had acquired UK domicile, at which point it ceased to be excluded property. It was subsequently transferred back again to the first settlement. The question in this case was whether such property re-acquired excluded status.