We’re dealing with an estate that comprises a significant property portfolio, some investments and bank balances.
The property portfolio passes via specific legacy, with residue going to a different beneficiary.
Both the legacy and residue will bear IHT, but due to the value of the assets and liquidity, IHT will be paid by instalments, which will result in interest being paid to HMRC.
My question is who should bear the cost of the interest on the IHT - should this be applied across both the legacy and residue, or is the interest solely borne by residue?
Any reference to case law or guidance would be much appreciated.