Allocating Testamentary Expenses

Looking for some help.

We have a Will which leaves a specific gift of “all bank and savings accounts to my grandchildren”, then a right of occupation in a share of a property to daughter (ends when she vacates the property). At the end of the right of occupation, cash legacies are payable from this share and then residue to daughter.

The only cash assets are a small bank account and a small shareholding.

The shareholding will form part of the residuary estate (daughter is the res ben).

There is a memorial stone which needs to be paid for and then estate costs to include solicitors fee for estate admin and disbursements.

The shareholding will not cover all these costs.

We assume that the right of occupation is classed as a specific gift and in any event funds cannot be accessed from the property until this is sold

Our questions are​​​​​​​:-

Does this mean that the estate costs - sol fees and disbursements should be paid firstly from the shareholding (as residue) and then from the bank accounts (specific gift).

If there are not sufficient funds from both the shareholding and bank accounts to cover all the fees - who is responsible for payment of the balance?

Any help would be greatly appreciated.

Thank you.

Gill Collins

In a solvent estate the duty of the PRs is to pay "funeral, testamentary and administration expenses, debts and liabilities payable thereout in the order mentioned in Part II of the First Schedule to this Act: s34(3) AEA 1925. [where any of these is charged on specific property that property is primarily liable to pay the debt secured on it : s35.The expenses you mention will not already be charged on any estate asset.]

Sch 1 works as follows:

1 There are 7 categories of assets and resort to them should be in numerical order. [ the testator can vary the order.] The first is rare so the second, residue, is the normal first resort, as you realise. The third, fourth and fifth categories are also rare so normally the next in line is the sixth: specific gifts. The remainder to the daughter’s right of occupation is not residue for this purpose even though understandably you describe it as such.

2 not stated is the equitable doctrine of marshalling which means that any one whose gift is reduced or eliminated has recourse to any property in an earlier category which for whatever reason has not been fully used. This will be otiose here if residue is fully used first as you anticipate.

Usually the legatee of a specific gift will undertake to pay the creditor and charge the gifted property on agreed terms but here the gift is not outright and the type of expense is such that the PRs need it to be actually paid promptly. The quirk in your case is that the specific gift is not even a life interest trust of liquid assets which otherwise could easily be used to fund the reimbursement.

The right of residence beneficiary or the remaindermen need to pay up, or the PRs personally if non-professionals, if needs be by borrowing, to avoid a sale of the property. This is plainly not what the testator envisaged and would be a disproportionate remedy, however legitimate. Reimbursement out of the trust asset when the remainder vests in possession can be agreed and an equitable charge taken over the trust fund. The daughter is the obvious candidate to pay because not only does she have a clear vested interest in preventing a sale but it may well be that her remainder share will be worth much more than the pecuniary legacy remainders whose beneficiaries may not get their money for a long time hence.

Jack Harper

| gill.collins
28 July |

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Looking for some help.

We have a Will which leaves a specific gift of “all bank and savings accounts to my grandchildren”, then a right of occupation in a share of a property to daughter (ends when she vacates the property). At the end of the right of occupation, cash legacies are payable from this share and then residue to daughter.

The only cash assets are a small bank account and a small shareholding.

The shareholding will form part of the residuary estate (daughter is the res ben).

There is a memorial stone which needs to be paid for and then estate costs to include solicitors fee for estate admin and disbursements.

The shareholding will not cover all these costs.

We assume that the right of occupation is classed as a specific gift and in any event funds cannot be accessed from the property until this is sold

Our questions are​​​​​​​:-

Does this mean that the estate costs - sol fees and disbursements should be paid firstly from the shareholding (as residue) and then from the bank accounts (specific gift).

If there are not sufficient funds from both the shareholding and bank accounts to cover all the fees - who is responsible for payment of the balance?

Any help would be greatly appreciated.

Thank you.

Gill Collins

Thank you so much for your clear information.

As the specific gift of the bank accounts and the right to occupy are both specific gifts, they will abate together.

However, has the right of occupation failed – consider the judgment in Hall v. HMRC [2023] UKFTT 00032 (TC)?

If it does fail, can the share of the property be realised to satisfy “its” share of the shortfall? That could be the more problematic aspect, upon which Jack has already commented.

Paul Saunders FCIB TEP

Independent Trust Consultant

Providing support and advice to fellow professionals

With specific gifts, I thought gifts of personalty abated before realty but I can’t recall my authority for this.

Any historic difference in treatment did not survive the 1925 reforms.

Jack Harper

The PRs can resort to any asset to pay admin expenses, tax, and other debts and liabilities. No doubt in practice they will resort first to readily realisable assets which are more likely to be personalty (the main exception being unlisted shares).

They should not unnecessarily sell any property specifically given (as that was not the testator’s presumptive wish), at least not before exploring other options like borrowing and charging the property after discussion with the legatee who may even be prepared to provide temporary funding to delay or prevent a sale.

This is a distinct operation from the AEA pecking order which applies where the estate is solvent to determine how the PRs’ above decisions impact upon the various legatees inter se. A specific legacy, personalty or realty, is well down the list but the legatee cannot resist the asset being sold by the PRs if they need to though they will be slow to do so. The legatee’s remedy is to be compensated if possible by the reduction or elimination of the entitlements of those in earlier categories.

Of course, an estate can be solvent but inadequate to meet all the legacies once residue has been exhausted and if even after abatement of pecuniary legacies the specific legatee may have to put up with only part of the sale proceeds of his gifted asset. Testators and advisers sometimes do not pay sufficient attention to how liabilities will need to be met and how this might compromise their plans e.g. huge legacies to Tom Dick Harry and the chauffeur which exhausts the residue for the unfortunate surviving spouse.

Jack Harper