Kesme and Soba, a married couple, require advice on the assets which will be received by Soba under Kesme’s will.

Kesme:
– Was born on 1 June 1940.
– Is UK resident and UK domiciled.
– Is married to Soba.
– Has not made any lifetime gifts for the purposes of inheritance tax.

Soba:
– Is UK resident but non-UK domiciled.
– Has elected to be treated as UK domiciled for the purposes of inheritance tax.

Kesme’s estate and his will:
– Kesme’s share of the family home, a plot of land and chattels are worth £1,280,000 in total.
– The plot of land is worth £370,000 and is situated in the UK.
– Kesme has left the plot of land to his daughter.
– Kesme has left the residue of his estate to his wife, Soba.

Required:
(c) Explain the implications of the election made by Soba to be treated as UK domiciled for the purposes of inheritance tax. (2.5 marks)