Gift of single nil rate band

Hello all,

I am drafting a Will for a married couple. W is a widow with full TNRB available from that previous death. H was not married before.

In order to take advantage of all 3 nil rate bands I intend to (on first deaths) make a gift of the nil rate sum to a DT. However, I want to ensure that she only uses up a single NRB on her first death (and not double). This is for practical reasons (she has about £325k in cash and a house). They’re a bit twitchy about putting a full £650k into the DT (although I accept that this would work from a tax perspective).

Is this the right solution? If so, I am struggling with the drafting. All the precedents describe the nil rate sum as the ‘maximum amount that can be left without IHT…’ etc…

Is it as simple as saying something like… the nil rate sum is an amount equal to the nil rate band for inheritance tax at the date of my death…or similar?

Am I missing something?

Also, the IHT402 doesn’t seem to be able to cope with this on the second death - it doesn’t appear to take into account any TNRB from a previous death…

Many thanks

Wondered if you managed to get to the bottom of the correct definition for the nil rate sum applicable in these circumstances as I now have a similar matter on my desk?

It’s not exactly what you’re after, but I have seen precedents that exclude the RNRB that include something along the lines of “provided that my Trustees shall not make a claim under s. 8D IHTA in respect of this clause”. Could it be adapted to fit your situation by saying that the trustees shouldn’t claim TNRB? I’m not sure so would welcome others’ thoughts on this.

I think the usual clause gifting the ‘maximum amount that can be left without attracting an IHT liability’ can still be used, but with post-death planning. This is because the DT can receive the full £650,000 and then within 2 years appoint out the extra £325k which will be read back under s144.

Not an ideal solution, but still a possibility.

Ihsan Ali
I Will Solicitors Ltd