I am resident in the Isle of Man (IOM). I have investments listed with a London broker. Are shares which are designated as an investment trust and situated offshore but listed on the London Stock Exchange (LSE) subject to inheritance tax (IHT)? For example, Pershing Square Holdings (PSH) is listed on the LSE but is situated in the Channel Islands. 

Arthur Weller replies: 

The Isle of Man (IOM) has a separate domicile from the UK. So, I am assuming (for the purposes of this question) that you are non-UK domiciled and non-UK deemed domiciled. If so, you are subject to IHT in the UK only on your assets located in the UK. In the Inheritance Tax Manual at IHTM27121 to IHTM27150, HMRC refers to the location of securities. The general rule is that a security (or shares) is located where the place of the register is situated.