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HMRC internal manual

Inheritance Tax Manual

From
HM Revenue & Customs
Updated
, see all updates

Foreign property: discretionary trusts and exempt securities: unknown persons

The legislation refers to ‘known persons’. So, when considering the question of domicile and ordinary residence you should not consider the possibility that some (currently) unknown person (for example an unborn child or future spouse or civil partner (IHTM11032) of an existing beneficiary) might become a beneficiary in the future.