Commentary

I5.361 Same-day additions

IHT, trusts and estates

I5.361 Same-day additions

I5.361 Same-day additions

Prior to 2015, a simple technique could reduce ten year charges involving the use of two or more trusts. First, pilot trusts with nominal capital would be set up, usually on different days but that was not essential. The funds to be settled on each trust were then transferred to the pilot trusts on the same day. None of the settlements would then be related settlements and each transfer made on the same day would not be taken into account in the calculations of the other settlements concerned.

This technique was particularly appropriate for trusts to be set up under a Will, since in the ordinary course of events all the settlements created under the Will would be related settlements. However if pilot trusts were set up during the lifetime of the testator, he or she could then leave funds to the trusts by the Will and these would then be additions to existing settlements, all treated as made on the same-day and therefore left out of account for

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