s.142 IHTA '84 can be used to prevent the “spread” of reliefs where s.39A IHTA '84 interaction applies. Does the same happen under s.144 IHTA '84?
For example, take a discretionary will trust over residue which includes a mixture of relievable and non-relievable assets, and exempt and non-exempt beneficiaries. Say an appointment to a non-exempt beneficiary is executed within two years of death and the specific asset(s) is a qualifying interest in a farm business worth £2.5m. Only IHT reliefs have been claimed on the specific asset(s) being appointed. The remainder of the estate is appointed on an IPDI for spouse and the spouse exemption claimed. Will this prevent the “spread” of reliefs under s.39A IHTA '84?