I have a client who has an estate iro £1.1M, which includes a property iro £200k. She is widowed and we have a TNRB available for use.
Her priorities are simplicity, to ensure that as much as possible can pass to her only son free of IHT and that overall there is no IHT to pay. She has spoken with her IFA and told me that she would like to make a gift to her son of the IHT allowances. The rest of her estate is to pass to charities.
I am considering the suitability of this option, as well as other ways in which her aims can be achieved (e.g. Disc Trust and sort it out later).
If she is keen to press ahead with the gifting of the allowances, I am unsure what RNRB + TNRB may be available to us, putting aside the value of the property for a moment.
As he is the only non-exempt beneficiary, will he be able to use the maximum amount of RNRB + TNRB or will the RNRBs be apportioned and all beneficiaries treated as owning a share of the property? I am leaning towards the former but have not come across express guidance yet.
I would be grateful for any thoughts and any precedents for such a clause that anyone has come across!