Wife owns a property and leaves this in a Life Interest Trust for husband (second marriage). Husband now intends to release his life interest and accelerate the terms of the Trust. This will be a PET for IHT purposes.
I understand that IHT attributable to failed PETs are assessed on the recipients but am not clear as to how to protect the Trustees in this situation; there are many reversionary beneficiaries who will share in this PET.
A claim for spouse exemption was made on the value of the property passing into the estate. CGT will not be an issue as Husband has remained in occupation [until likely sale].
How would practitioners deal with this in case husband were to die within 7 years?
Brewer Harding & Rowe