997. Two year discretionary will trust.

Where property comprised in a person's estate1 immediately before his death is settled2 by his will and, within two years after his death and before any interest in possession3 has subsisted in the property, an event occurs:

  1.  

    (1)     on which tax would otherwise be chargeable under the provisions relating to settlement without interests in possession and settlements in which interests in possession subsist4; or

  2.  

    (2)     on which tax would be so chargeable but for its becoming subject to employee trusts5, held for charitable purposes only6 or in a fund for maintaining certain buildings for the public benefit7,

then where an