I3.266 Transfers between spouses and associated operationsOne problem that has been discussed in connection with IHTA 1984, s 268 has been the use of arrangements to make use of other people's annual exemptions, or nil rate bands. Now that there is potential exemption (I3.311–I3.319) the use of annual exemption is of less interest, but on the other hand the nil rate band is much increased. There is also the desirability in some circumstances of channelling a gift through someone with a longer expectation of life, and with a better chance of surviving the seven years so as to make a potentially exempt transfer completely exempt.The usual operation involves a spouse or
One problem that has been discussed in connection with IHTA 1984, s 268 has been the use of arrangements to make use of other people's annual exemptions, or nil rate bands. Now that there is potential exemption (I3.311–I3.319) the use of annual exemption is of less interest, but on the other hand the nil rate band is much increased. There is also the desirability in some circumstances of channelling a gift through someone with a longer expectation of life, and with a better chance of surviving the seven years so as to make a potentially exempt transfer completely exempt.
The usual operation involves a spouse or
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