Apportionment of IHT

My client died in 2016 leaving a lifetime interest in the family home to his wife plus income from his residual estate.
On her death her personal estate passes to her children, the family home passes to her late husband’s sons and his residual estate passes to the wife’s son.
Am I correct in saying that IHT would be apportioned three ways?
Assuming the following: Wife’s personal estate is £ 300,000; the family home is £ 500,000; the husband’s residual estate is £ 280,000. Total: £ 1,080,000 less allowances of £ 675,000, tax payable £162,000.
If the wife were to relinquish her entitlement to income from the residual estate now, is IHT payable immediately at 40% (husband’s estate used up his personal IHT allowance) by the Trust?

David Moore
Estate Preservation Ltd

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