Life Interest Trust - IHT

Sorry if I’m being thick, but I’m having a senior moment.

Husband dies leaving an estate of £1M in a life interest trust for his (second) wife and then on her death to a charity.
Upon wife’s subsequent death, her estate is worth £100,000.
The total taxable estate is therefore £1.1M with the Life Interest Trust being aggregated with her estate.
After deduction of both IHT allowances (ignoring the residential allowance for this question), this leaves a chargeable estate of £450,000. IHT at 40% giving a IHT liability of £180,000.
Who pays this IHT?

christopher james
davies and partners

Is there any reason why the £1 million in the IPDI is not covered by charities exemption?

But assuming any IHT is actually due on the combined estate/IPDI, the tax is divided pro rata between the trust and the estate.

Taurean Drayak
Elliot, Bond & Banbury