Q. With the abolition of domicile for tax purposes, can my clients benefit from foreign capital losses. As background, the client has been resident in the UK since the 2023-24 tax year with remittance basis claims made for each of those tax years and did not make a foreign capital loss election.

A. Pre-6 April 2025, unless an individual made a foreign capital loss election under TCGA 1992, section 16ZA, any foreign capital losses, as a loss accruing on disposal of an asset situated outside the UK, s16ZA (6), were not allowable losses for CGT purposes, s16ZA (3) for that tax year, or any subsequent tax year except when UK domiciled.