Commentary

I5.355 Calculating the ten-yearly charge examples

IHT, trusts and estates

I5.355 Calculating the ten-yearly charge examples

I5.355 Calculating the ten-yearly charge examples

Example 1—hypothetical value transferred

The facts are as I5.318 and can be summarised as follows:

  1.  

    •     Eliza transferred property then worth £600,000 on 26 July 2005 into a new settlement executed on that day.

  1.  

    •     Under the trusts of that settlement half the settled property was subject to an interest in possession of the settlor's son, Ian, and half was held on discretionary trusts.

  1.  

    •     Also on 26 July 2005 Eliza made a separate 'related' settlement of property then worth £100,000.

  1.  

    •     Ian died on 5 December 2009, after which all the property in the settlement was held on discretionary trusts.

  1.  

    •     On 10 June 2011 an appointment was made in the manner and with the

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