The couple put their property, then valued at £500k, into two DTs (one half value of the property into each trust) in 2013. It’s now worth £800k and they are worried about IHT. Other assets are worth about £150k.
They want to know if they can benefit from the RNRB with the property in trust, or if they should it out of the trusts to benefit and if so how.
I don’t think there is anyway the RNRB would be available at the moment, and there would be a potential IHT bill on death of £120k. If the double RNRB was available there would be no tax to pay on their estate??
I agree with your assessment. The gift was, presumably, a gift with reservation of benefit (GROB), and GROBs can benefit from the RNRB only if the beneficiary of the GROB is a lineal descendant, which in this case it is not. They would need to extract some part of the property from the trust, and leave it to a lineal descendant, (or make a GROB to a lineal descendant) in order to benefit from the RNRB.