Expat Tax Architecture

UK Non-Dom 4-Year Foreign Income and Gains (FIG) Transition

Audited by Cole Barrett • Topic: Expat Tax Architecture
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Cole Barrett's Reality Check

The Unvarnished Bottom Line

"The UK killed the historical 200-year-old remittance basis for non-doms and replaced it with the 4-year FIG regime. You get four years of tax-free offshore income and gains, and you can bring the money into London without paying a penny. But on April 6 of year five, the clock expires: your worldwide portfolio gets pulled into HMRC’s full UK tax net."

Interactive Simulator: Test the Math

Interactive Simulator: Compounding Fee & Tax Drag

Portfolio Balance ($) $100,000
Annual Expense / Tax Drag Rate (%) 0.75%
Direct Annual Deduction
$750.00 / yr
Siphoned directly from capital
25-Year Compound Loss
$94,200
Lost growth potential

Real-World Example: Scenario Breakdown

Examining the real numbers for: An international executive relocating to the United Kingdom holding an offshore investment portfolio generating £150,000 in annual foreign capital gains

Execution Metric 4-Year FIG Regime Beneficiary Year-Five Unprepared Resident
Fee / Rate $0 remittance charges $0 account fees
Spread / Buffer Met the prior 10-year non-residence test; claimed the statutory 4-year Foreign Income and Gains (FIG) tax exemption Remained resident in the UK into Year 5 without restructuring offshore accounts or utilizing pre-transitional basis step-ups
Execution / Status Remitted £150,000 in foreign investment gains directly to a UK bank account to purchase a London home FIG exemption expired on April 6 of Year 5; worldwide investment portfolio entered full UK tax scope
Total Cost / Result Freely remitted offshore capital to the UK tax-free during the 4-year window Subjected to full UK worldwide taxation upon expiration of the 4-year FIG window

How Brokers Weaponize This Term

If you reside in the UK under the 4-year FIG regime, calendar your fourth tax anniversary. Prior to April 6 of your fifth year of UK residence, execute tax-efficient offshore portfolio basis step-ups or establish excluded-property trust structures to shield legacy wealth from incoming UK worldwide taxation.

Broker Evaluation Matrix

Cole Approves

Interactive Brokers: Provides institutional multi-currency custody accounts with clean segregation of pre-residence capital, foreign gains, and domestic UK funds.

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Cole Flags / Avoids

Traditional UK High-Street Banks: Commingles offshore foreign income with UK funds, complicating tax audit trails under HMRC mixed-fund rules.

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Frequently Asked Questions

Can you bring offshore funds into the UK under the FIG regime without tax?

Yes. Unlike the legacy remittance basis regime, qualifying income and gains generated during the 4-year FIG window can be freely brought into the UK with zero UK tax liability.

What is the Temporary Repatriation Facility (TRF)?

The TRF is a transitional measure allowing former non-doms to remit un-remitted foreign income and gains accumulated under the legacy remittance regime to the UK at a reduced, preferential tax rate (e.g., 12% to 15%) for a limited window.