I have a query regarding the apportionment of the Residence Nil Rate Band.
Where a deceased testator gives ‘such some or property’ up to the value of the Nil Rate Band to his Trustees (NRBDT) with 90% of his residuary estate passing to his children and 10% to charity. Does the QRI fall entirely with the residue or does it have to be apportioned between the children, charity and NRBDT?
The difference would be claiming 90% of the RNRB (if it falls within the residue) oppose to around 55% if it has to be apportionment to include the NRBDT.
Hill Dickinson LLP