I am dealing with an estate where there are some pecuniary & specific legacies to some non-exempt beneficiaries free of tax & a NRB legacy to the deceased’s daughter which is worded as follows:
Such sum as is equal to the amount which is the upper limit at the date of my death of the first nil-rate portion value referred to in section 7(3) of the Inheritance Tax Act 184 in accordance with section 8 of he Inheritance Tax Act 1984 but reduced by the aggregate of the values transferred by previous chargeable transfers made by me in the period of seven years ending with the date of my death and in this clause the terms “values transferred” and “chargeable transfers” have the same meaning as in the Inheritance Tax Act 1984
The residue is left to the surviving spouse.
So does the daughter receive £325,000 less the amount of the gifts in the Will or do I have to gross up the gifts?
Rose & Rose