Malcom
S.142 is a rather blunt tool, HMRC does provide guidance with Inheritance Tax: instrument of variation checklist (IOV2). It clearly states “who” is to benefit must be included in the variation.
The Property Act is very clear on the definition of ‘who’, for the purposes of wills an instruments. Who: can be a person or corporation.
I’d suggest this is why s.142 is silent. It would simply repeat the previous act.
Richard Bishop
PFEP