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Old 08.06.2019, 23:43
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Re: Buying VTI - potential estate tax liability in the US?

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You can only hold 1 domicile, someone with British domicile will not loose it even after 10 years of living in CH.
Assuming loose meant lose, at the time of writing it took 12 years to become Swiss but since 2018 it’s 10 if you have a C permit upon application. This introduces a new possibility/anomaly which may not yet have been tested in case law. A person with British domicile in Switzerland could naturalise and could then argue to have Swiss domicile as a Swiss resident and citizen and taxpayer while in Switzerland they become Swiss-only once naturalised, just as in the US. Domicle could be restored to the UK upon change of intent (otherwise the Swiss naturalisation could be questionable).

(See Boris Johnson”s article on having to apply for a US passport when transiting the US by virtue of being born there, which required him to be liable to US capital gains tax on a UK property sale while UK resident, pending his later renunciation-which domicile do you think the UK tax authorities believed he had in London notwithstanding his US expat tax liability while remaining a US citizen under US law?), as a UK citizen and tax resident?
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Old 09.06.2019, 11:07
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Re: Buying VTI - potential estate tax liability in the US?

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Assuming loose meant lose, at the time of writing it took 12 years to become Swiss but since 2018 itís 10 if you have a C permit upon application. This introduces a new possibility/anomaly which may not yet have been tested in case law. A person with British domicile in Switzerland could naturalise and could then argue to have Swiss domicile as a Swiss resident and citizen and taxpayer while in Switzerland they become Swiss-only once naturalised, just as in the US. Domicle could be restored to the UK upon change of intent (otherwise the Swiss naturalisation could be questionable).

(See Boris JohnsonĒs article on having to apply for a US passport when transiting the US by virtue of being born there, which required him to be liable to US capital gains tax on a UK property sale while UK resident, pending his later renunciation-which domicile do you think the UK tax authorities believed he had in London notwithstanding his US expat tax liability while remaining a US citizen under US law?), as a UK citizen and tax resident?
Clearly by breaking all ties, a domicile of choice can be established, however if you leave that country you automatically revert to your domicile of origin as far as the UK is concerned.

Without knowing the domicile of BJ's father I can't answer the question, if his father had a UK domicile he undoubtedly is UK domiciled, being born in the US is irrelevant. Without a UK domicile there is no IHT exemption between husband & wife.
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