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� what the individual needs to do in order to become UK resident under the statutory residence test , and when UK residence will commence . This can be very fact-specific .
Changes that are likely to be needed to the individual ' s banking arrangements before UK residence commences .
Whether there is scope for investments to be " re-based " prior to the commencement of UK residence . The purpose of " re-basing " assets is to ensure that gains on a later disposal are calculated by reference to market value of the investments shortly before UK residence commenced , rather than the original acquisition cost of the investments . Unlike many countries the UK does not have a rule that automatically " re-bases " assets when an individual becomes resident .
6 . How investments should be selected and managed ? Whether it might be beneficial for the individual to make an election to HMRC , to give him the ability to make use of foreign losses ( i . e . set losses realised on the disposal of non-UK assets against gains , for UK tax purposes ). Generally , UK resident non-domiciles are unable to make use of foreign losses . After a nondomicile has become UK resident for the first time , as a remittance basis user , he has a one-off opportunity to make an election so that foreign losses can be used . However , there are pros and cons of making such an election . For some nondomiciles it is preferable not to make the election , and for many others it is difficult to predict whether the election will make economic sense or not . In practice , relatively few individuals do make the election .
If the individual will be purchasing a UK home ( rather than renting one ), how the purchase should be structured for UK tax efficiency . For UK residents , holding vehicles such as companies and trusts are rarely advisable , but it may make sense ( even for a cash-rich purchaser ) to use mortgage finance when purchasing a UK home . This is to achieve a deduction from the value of the home for inheritance tax purposes . Such a deduction can , generally , no longer be achieved if mortgage finance is obtained after the purchase .
7 . Bank account management Remittance basis users typically need to adopt specialised bank account arrangements . These apply to cash accounts and often also to investment accounts . The aim is to ensure :
� that clean capital is not mixed with foreign income or gains , � that UK expenditure is funded from clean capital , and conversely � that non-UK expenditure is funded from foreign income or gains .
It is essential that advice is taken on such arrangements and that they are put in place before the commencement of UK residence , so that there are no inadvertent remittances to the UK of non-UK income or gains , and so that the stock of clean capital that the individual has at the start of UK residence is not contaminated or