Limit on Exercise of Trustee Powers

My client’s wife had instructed other solicitors to prepare her will, but she did not execute it prior to her death. I have been asked to advise the husband on the suitability of a deed of variation drafted by those lawyers.

The varied provisions of the notional will are as follows:

• The personal chattels are left to the three children with a request that they, within 6 months of her death, dispose of them in accordance with wishes.
• Her shares in the limited company and any assets used by it are left on a discretionary trust.
• All three children are trustees of the residue. The husband is given a life interest in the income. The trustees have a power to appoint capital to the husband. Subject to those provisions and the exercise of the overriding power of appointment, the residue passes to the children.
• During the Trust Period, the trustees have power to appoint any part of the trust fund and its income to any or all of the Beneficiaries. There is also a power of advancement to benefit any or all of the Beneficiaries and a power to transfer to another trust provided at least one of the Beneficiaries has an interest in that trust.
• The will makes clear that none of the provisions can be exercised if that would prevent a person having an interest in possession under s.49(1A) IHTA 1984 or prevent s.71A (trusts for bereaved minors) or 71D (18-25 trusts) applying.

This last provision confuses me. To what extent can the trustees of the residue still exercise their overriding power of appointment?

Thank you for the help.

Presumably the purpose of the DoV provision is to prevent the mere existence of the power from getting in the way of s.49/71A, 71D applying while the relevant trust subsist. That’s much more important in relation to s.71A and s71D than s.49 as the ability to advance away from a s.71A trust to another beneficiary would prevent s.71A applying in the first place.

I hope that makes some sense!

Whether it works in this way, or actually blocks any exercise of the power over the IPDI assets whatsoever, will depend on the exact wording.

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