U.K. Discretionary Gift Trust & Japansese Gift / Inheritance Tax

[Crudzilla]

Usual caveats, but your option 3 sounds worth investigating to me. You have never actually had possession of any money as far as I can see, and if there is no trust anymore there is no gift...

If that were possible, would you not be better off waiting to actually inherit rather than go down the gift route? Apologies if I have missed something and you need the money now for whatever reason.

Thanks for reading through everything Beaglehound. Yes, option 3 is also appealing (especially in its simplicity). The only caveat being, the exchange rate happened to be very favorable at the time of the trust's establishment. I could easily fit the full amount in the inheritance tax allowance at that rate, with room to spare should I need it later, but at the current rate, it would overflow it and leave nothing for later.

There is a reason to bring the money to Japan. Mostly that, as a foreign resident, I cannot easily invest the money in the UK. That is why the trust seemed best, because it allowed the money to be invested and managed by the trustees (because I am barred from doing so). My father could invest the money personally and let me inherit it at a later date, but by that time it would have grown even larger...

But closing the trust down recieveing at least the 25m that can be deferred to inheritance (tax free) is also a strong option, and one that requires much less interpretation on the nuances of Japanese tax code.

[Tkydon]

There is always the Early Inheritance Clause which would allow you to receive Y25M Free of Gift Tax now, but have it included in the Estate for Inheritance Tax when your father passes.

https://retirewiki.jp/wiki/Inheritance_ ... d_tax_code

[Crudzilla]

There is always the Early Inheritance Clause which would allow you to receive Y25M Free of Gift Tax now, but have it included in the Estate for Inheritance Tax when your father passes.

https://retirewiki.jp/wiki/Inheritance_ ... d_tax_code

Yes, I will almost definately be using that clause (as outlined in my monster post earlier)
I am hoping I could apply it retrospectively (to the amount 'gifted' when the fund was set up).
Do you know if that would be possible?
Also do you know anything about the pentalties that would be incurred on a tax declaration and payment that is now 7 years late?!

[Tkydon]

There is always the Early Inheritance Clause which would allow you to receive Y25M Free of Gift Tax now, but have it included in the Estate for Inheritance Tax when your father passes.

https://retirewiki.jp/wiki/Inheritance_ ... d_tax_code

Yes, I will almost definately be using that clause (as outlined in my monster post earlier)
I am hoping I could apply it retrospectively (to the amount 'gifted' when the fund was set up).
Do you know if that would be possible?
Also do you know anything about the pentalties that would be incurred on a tax declaration and payment that is now 7 years late?!

Probably not possible, but could you claim that the money was Inheritance from your Grandfather?

Under Japanese Inheritance Law, you can be assigned Inheritance by the Executor of the Will, even if not specifically named in the will...