Pre-2006 A & M Trust
An A & M Settlement was created in 1992 for four beneficiaries, grandchildren of the Settlor.
The trustees now wish to transfer the assets to the beneficiaries and wind up the Settlement.
As was typical, the beneficiaries were given a right to income with effect from their 25th birthdays, with the Trustees given a right to hand over the capital absolutely when they see fit, subject to (what was then) the 80 year limit.
The beneficiaries were all born in the 1970s and turned 25 before the 2006-2008 changes in Trust rules.There have been no changes in the structure or the beneficiaries since inception.
Am I right, therefore, in thinking that the Settlement in question should now be regarded simply as a pre-2006 Interest in Possession Trust for CGT/IHT purposes? This would mean that there would be no Section 260 hold-over relief on the transfer of the assets to the beneficiaries, so there might be CGT to pay. On the other hand, we would not be looking at an IHT exit charge?
Thanking you in advance.
- Small employers paying people when sick thanks alot! 3,148 35
- Starting up in practice - safety net 222 6
- PAYE coding notice - deliberate misstatement 350 9
- Can Excel sheets be imported into Digita Accounts Production Posting Sheets? 109 1
- Director's current account - fuel costs and expenses 344 11
- How to avoid PAYE Registeration 238 4
- Rental property company 114 1
- How quickly do you turn around y/e accounts? 332 7
- Payroo Employer allowance query 266 8
- Enforcing A CCJ 387 7
- RTI 'Late Filing' & paying employees in arrears 167 1
- Reporting no P11d due when PAYE scheme closed by HMRC 5Apr2013 204 2
- Comapny valuation qualifications 151 2
- Ex Client from over 3 years ago 509 5
- Director's tax return 402 8
- Sale of assets - availability of AIA to the purchaser 189 3
- Flat rate vat 249 2
- RTI Annual Scheme Query 201 5
- Coming in from the cold 404 3
- Splitting the tax year 199 2
- Residential Property Purchase Above £750K 823
- Using Sage with Sofa Categories 572
- Does anyone have an unwanted ICAEW wooden plaque? 441
- Goods shipped inter EU and VAT Reporting 321
- Free Tax Legislation? 294
- Director Loan account operation 273
- Non-Resident Director - UK Tax Position? 263
- transferring simply accounting 2010 from xp to windows 7 260
- Sage 200 and Access Dimensions reviews 239
- Paye procedures for CVA 181