That’s a wrap

Will an additional permitted subscription to an ISA count as a chargeable event?

A client’s husband had an individual savings account (ISA) portfolio of about £500,000 when he died.

I understand that between death and the date of the additional permitted subscription (APS) being made, the portfolio will be subject to tax in the normal way. After the APS, the portfolio regains its tax-exempt wrapper.

However, is there a need to consider the gains and losses of the underlying investments between the date of death and the APS, and are these therefore subject to capital gains tax?

Taxation readers’ thoughts on this matter would be gratefully appreciated.

Query 18,940– Portfolio.

An asset transfer

Will the transfer of assets abroad rules apply on transfers before living in the UK?

Our client, Tommy, arrived in the UK in 2015-16 to closely manage TradeCo, a trading company incorporated and based in the UK of which he has been a director since its incorporation three years ago.

Under the statutory residence tests, Tommy is now UK resident although he has retained his foreign domicile. He has elected to use …