I am dealing with a qualifying A&M Trust (i.e. an A&M Trust which satisfies the conditions under 71D(6) IHTA 1984 so is taxed in the same way as an 18-25 trust). The two beneficiaries are now aged between 18-25 and capital distributions have been made which will incur an exit charge.
The IHT100 directs me to form IHT100c for an 18-25 trust or form IHT100e for special trusts which the guidance tells me should be used for ‘assets held in an accumulation and maintenance trust which no longer meets the conditions needed to benefit from special tax treatment for any reason other than the beneficiaries becoming entitled to a benefit on reaching a specified age’. This latter would seem to refer to A&M trusts which do not satisfy the 71D(6) conditions. However I do not find the guidance clear and neither form seems to ‘fit’ the information that I consider should be provided.
I have called HMRC IHT helpline several times and been promised a call back from Technical but I never get one.
I wondered if anyone had experience of completing an IHT100 for this type of trust (or indeed for an 18-25 trust, for which the forms and guidance also do not seem to ‘fit’ - I can’t understand why the HMRC guidance seems so lacking, but perhaps I am missing something)?
Phillips Lewis Smith