I would be grateful for any comments on the following:
A and B were married. B died second. B’s estate is £2.9 million. B’s estate contains a QRI passing to lineal descendants. At A’s death, A’s estate qualified for the RNRB. A’s net estate was £1 million.
My understanding is that even though there is an unused RNRB from A’s death that is ‘brought forward’, as B’s estate is in excess of the sum of £2 million plus £700,000 (the combined RNRBs after tapering) then B’s PR’s cannot claim any RNRB.
Yes, that is my understanding too, in that B has a 100% enhancement and so has an RNRB of £350,000. As you say, as the estate is above £2.7m then it tapers to zero anyway, but remember that the value of the estate used is not the same as that for IHT, so before any reliefs and exemptions, and does not include the value of gifts in the previous seven years.