The recent case of Carvajal v HMRC has put a spotlight on the risks and complexities of last-minute inheritance tax (IHT) planning. This case involved Mrs. Fleet, a UK taxpayer who sought to reduce the tax bill on her estate shortly before her passing.

From April 2025 the UK’s inheritance tax (IHT) system moved from a domicile‑based framework to a residence‑based regime. This shift means that individuals who meet the definition of a long‑term UK resident will be exposed to IHT on worldwide assets sooner than before. Understanding when assets are treated as excluded property—and therefore outside the scope of IHT—is now critical for families and trustees with cross‑border connections.

He built an international career in finance, bought a flat in Zone 2, kept the family holiday home in Abruzzo, and – on the advice of a banker friend – settled some investments into a trust in Jersey “for succession planning”. His wife, Francesca, preferred to stay mainly outside the UK, coming over only for short periods.

Alessandro moved to the UK in the late 1990s with a suitcase, a degree in engineering, and big hopes for the future. Twenty-five years later, he lives in Surrey with his wife Elena and their two children, Sofia and Marco. He's now a British citizen, owns a family home in the UK, and considers himself firmly rooted in British life.