Disclaimer of Trusteeship Required?

The deceased’s Will appoints the partners of the firm of solicitors drafting the Will to be the executors and trustees of the Will. There is no successor clause and at the date of the deceased’s death, the firm that prepared the Will no longer existed.

There is no substitute executor named.

Two of the residuary beneficiaries have therefore acted as administrators of the estate.

The Will includes a six month right of occupation. The right of occupation never took effect and at no point since the date of death did the person with the right of occupation reside in the deceased’s property.

I understand, however, that there is a possibility that HMRC may regard the right of occupation as a life interest trust and treat it as such on the death of the person who had the right of occupation.

In the circumstances, would the partners of the successor firm need to sign a Deed of Disclaimer of Trusteeship to disclaim as trustees of the potential trust, or would this not be required as their appointment fails and instead the role of trustees has fallen on those acting as the administrators of the estate?

Any thoughts would be most appreciated.

The disclaimer should be completed by the person who was given to right of occupation.

Alternatively, the personal representatives might resolve that as the person given the right of occupation had not taken up such right and they are therefore considered to have disclaimed that right by their (in)action.

Paul Saunders FCIB TEP

Independent Trust Consultant

Providing support and advice to fellow professionals

As Paul indicates disclaimer can be by conduct though there must be sufficient evidence to support the argument. OK as a tabula in naufragio, as where the person who could make it is dead or has lost capacity. Otherwise writing preferably a deed is advisable s93 IHTA does not impose any time limit for making one though doubtless a court could consider laches. In practice s241 will place 4 years on it if the final tax bill on the estate has been paid. A COD does not prevent the recovery of additional tax caused by a disclaimer: s239(4)(a). Even so the 4 6 and 20 year time limits in s240 will operate.

Jack Harper