Commentary

I12.710 Sale into trust

IHT, trusts and estates

I12.710 Sale into trust

I12.710 Sale into trust

An alternative to the Melville trust structure is to set up a loan facility given by the settlor to the trustees, with this facility being drawn down by the trustees to purchase certain assets from the settlor. If the loan is interest-free and repayable on demand, and the assets held by the trustees are easily saleable, there will be no significant transfer of value on making a trust of this type.

If the settlor is a beneficiary of the trust, all the trust assets will be caught by the reservation of benefits provisions1 (Division I3.4).However some slight

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