United Kingdom: Inheritance tax on trusts |
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| Authors: | Davidson Diana |
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| Affiliation: | Correspondence: Email: ded@farrer.co.uk |
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The politics
| When the Government proposals for the amendment of inheritancetax were first publicised, there was a good deal of puzzlementamongst practitioners as to the point of principle involved.Although the proposals were called Aligning the inheritancetax treatment of trusts, their effect was to bring toan end the alignment of life interest trusts with absolute ownership.Instead, all trusts with very few exceptions will be taxed underthe harsher rules previously only relevant to trusts withouta life tenant. Such a beneficiary was previously equated withan absolute owner for the purposes of levying inheritance tax. When the draft law was debated in Parliament, it became clearthat the principle was that, in the Treasury's view, the passingof assets down the generations by means of a trust is tax avoidanceand an abuse. The Paymaster General,
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