IHTM20613 - Life Policies: policies with Canadian insurance companies: governing law
Policies issued by Manufacturers Life outside Canada usually contain a clause specifying which law governs the contract and are usually in the form prescribed by that law. Policies in England, for example, are usually in English form and governed by English law.
If the policy expressly refers to the Married Women’s Property Act 1882 (IHTM20181) you may assume that it is governed by English law.
If the policy is governed by the law of a Canadian province it will normally only be liable to Inheritance Tax if the life assured dies domiciled in the UK (to 5 April 2025) or a long-term UK resident (from 6 April 2025) or if the policy is situated here on their death. Guidance on issues of domicile, long-term UK residence and situs can be found in this manual in Chapter 13 (IHTM13001), Chapter 47 (IHTM47000) and Chapter 27 (IHTM27000).