Lettings allowance, as we know, comes into effect on 06/04/2020 for disposals on or after that date.
Imagine an elderly taxpayer living in a property qualifying as his PPR. for 15 years to 2001. He lets it residentially, and exchanges contracts on 03/04/2020, the last working day of 2019-2020. He gets lettings allowance based on 15 years, and a further PPR of 18months, plus 15years' lettings allowance up to a ceiling of £40,000. If his contract is dated 06/04/2020, he loses Lettings Allowance of £40,000 and the bit at the end is only 9 months. He is a basic rate taxpayer and his cgt rate is 18%. The tax on his lettings allowance is £5040.
So he decides to crystalise his gain by settling the property on his son well before 06/04/2020. He retains the income and his son is the remainderman. He might have been assessed on the income, but he would be getting it anyway. His estate is too small for inheritance tax to be an issue.
The downside would be the legal cost of setting up the Trust,. There would be an annual SATR for the trust , but he is competent to file that. Are there any other issues? (Apart , of course, from the fact that the Act may be amended in the next Budget so that relief is oinly lost from the date of the last Budget.)