IHT Calculation / Trust Fund(s) - Exempt and Non Exempt Beneficiaries

I’m working on a residuary estate of £3.5 Million. The deceased left the residuary estate to be split equally 50:50 into 2 separate equal funds for the following beneficiaries - one an exempt charity and the other a non-exempt individual.

Can i have clarification that:

  1. the 325k nil rate band is exempt from the £2 million taper (unlike the RNIB)
  2. does the non-exempt fund of £1.75 million receive the full £325k nill rate band allowance alone before IHT calculations (as charities are exempt and don’t count towards the nill rate band?)
  3. What type of trust is to be set up ? emphasized text My trustees shall hold my residuary estate as to both capital and income upon trust to be held by my trustees who shall divide the same into two separate funds.

Many thanks for input received