Jurisdiction(s):
United Kingdom

Client explanatory note: discretionary Will trust for unmarried partners with children—structure, trustees' powers, guardians, and IHT planning (including FA 2025 residence-based rules)

Precedents
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STOP PRESS: Abolition of non-dom regime and introduction of residence-based IHT regime

The Finance Act 2025 (FA 2025), which obtained Royal Assent on 20 March 2025, enacts the removal of the remittance basis of taxation, replacing it with a residence-based framework from 6 April 2025. FA 2025 likewise substitutes domicile as the primary factor for determining liability to inheritance tax.

Further measures include:

  • Revisions to the rules that define excluded property status;
  • The abolition of the protected settlements status of offshore trusts; and
  • Amendments to overseas workday relief.

For guidance on these developments, see Practice Notes: The abolition of the remittance basis of taxation from 2025–26 and A new residence-based regime for IHT from 2025–26. See also: Finance Bill Tracking Service: Key dates (Finance Bill 2025) and Finance Act 2025.

[Your ]Will—[ name of testator ]—[ explanatory note ]

This [ explanatory note ] outlines the main provisions of your Will. Please read this [ explanatory note ] and your Will with care...

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Web page updated on 22/05/2026

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