Estate CGT planning and TRS

Trusts Discussion
1

I would be grateful for members opinions as to whether the following is a registrable trust for TRS purposes:-

  1. Executors appropriate the beneficial interest in a property to a beneficiary for CGT planning purposes.

  2. Said beneficiary then assigns by deed a beneficial share to his spouse.

Legal title still rests with the executors with the beneficial title split between husband and wife. Whilst there is a bare trust, to my mind, it is not an “express trust” and therefore no registration is required.