We have quite an unusual case whereby the sole beneficiary of an offshore discretionary trust is charity. The settlor is UK resident and domiciled. We have little detail on the background.
The trustees wish to remove charity and replace it with family members with a view to making capital distributions
We are trying to ascertain the IHT treatment. Guidance would suggest that:-
- The removal of the charity would result in a Flat Rate Charge; and
- The value of the settlement would then be regarded as relevant property.
Any thoughts would be most welcome.
TFO Tax LLP