I am in the midst of a trust ten year anniversary calculation, and would appreciate some confirmation or otherwise of my method so far.
In summary, deceased died, leaving a Nil Rate Band discretionary trust, and residue on life interest trust for widow.
A deed of variation (effective for IHT purposes) appointed part of the Nil Rate Band discretionary trust on revokable life interest trust for widow.
Looking at the HMRC guidance for calculating the charge, I believe that in calculating the effective rate, I need to bring in the current value of the relevant property, together with:
- Initial value (i.e. probate value) of the non-relevant property (i.e. the element appointed to widow under the DoV), and
- Initial value of the related trust (i.e. the residuary life interest trust).
I have however also read s80 IHTA 1984, which is confusing me - my initial reading of this is that I can exclude both 1 and 2 above.
Can anyone confirm whether i’m reading this correctly, or point me in the right direction if i’m not?
Argents Chartered Accountants