Boodle Hatfield LLP

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Emma Haley

Boodle Hatfield LLP

Mark Lindley

Boodle Hatfield LLP

4 Contributions by Boodle Hatfield LLP Experts

Lifetime IHT Planning—Outright Gifts vs Trusts, Will Co-ordination, Timing, and CGT/Income Tax Implications
PRACTICE NOTES
From an IHT standpoint, the overarching purpose of lifetime planning is to arrange an individual’s assets during life so the eventual IHT burden on death is minimised. This can be done in several ways, including putting money into a range of tax-efficient holdings and identifying, securing and augmenting IHT exemptions available and valuable reliefs. A central element of lifetime IHT planning is both gifting during life to significantly shrink the overall estate that will be owned on death, and this Practice Note focuses on that theme. Lifetime IHT planning may equally entail creating or reviewing a person’s Will. Where a strategy blends lifetime transfers with Will structuring, the two strands should not be viewed separately. It is vital to consider the provisions of any Will when lifetime gifts are contemplated, and the converse applies. Even if a client chooses not to
Private Client
Pilot trusts and IHT after Finance (No 2) Act 2015: same-day additions, related settlements, Will planning, creation and merging
PRACTICE NOTES
A pilot trust is a lifetime settlement created with a token amount (often a nominal cash sum such as £10) and it remains inactive until more money or assets are later added thereafter. Setting up a trust in this fashion is very common indeed. The starter sum brings the trust into being so it stands ready to receive the principal assets at an appropriate future time. Pilot trusts in practice A great many trusts begin life as pilot trusts. The core assets of the trust might be introduced very shortly after the pilot starts. For instance, an individual intending to place property into trust could first establish a pilot and then soon after move UK land to the trustees by an HM Land Registry transfer. Equally, some pilots may not be topped up for several years and will largely lie dormant in the interim period. As
Private Client
Transfers between spouses and civil partners: UK IHT, CGT and income tax—spousal exemptions, FA 2025 long-term residence, anti-avoidance, separation rules, and planning using NRB, TNRB and RNRB
PRACTICE NOTES
It is common for spouses or civil partners to wish to give gifts to one another, as sharing possessions is a familiar feature of coupledom. This reflects the everyday reality of jointly owned property and pooled resources. The label ‘spouses’ in this Practice Note covers both married pairs and those in a registered civil partnership, of any gender. For clarity, the term is applied inclusively and neutrally. Balancing the pair’s holdings so each enjoys personal financial stability can be prudent, and it also opens up the widest opportunities for tax planning. For instance, where one spouse is taxed on income at a higher rate than the other, it is logical to shift more income-producing assets to the spouse taxed at lower rates. An equivalent approach works for capital gains tax (CGT): aim for each spouse to use their annual exemption on
Private Client
Woodlands Relief under UK Inheritance Tax: conditions, elections, deferred charges on timber sales or gifts, APR/BPR interaction, planning points; notes APR £1m cap from 2026 and UK land restriction
PRACTICE NOTES
FORTHCOMING CHANGE : In the inaugural Budget of the new Labour administration on 30 October 2024, the Chancellor of the Exchequer, Rachel Reeves, announced that the currently unlimited 100% rate of APR will be restricted to the first £1m of value, taking into account the value of business property relief held by the taxpayer and which is also eligible for 100% relief. This change is expected to take effect on 6 April 2026...
Private Client
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