- 1. The Scope of the Book: Estate Planning Introduced
- 1.4.4 The purposive approach
- 1.4.5 Three recent taxpayer successes
- 1.5.7 Transactions in securities
- 1.5.12 The three disclosure regimes
- 1.5.13 Two offshore disclosure regimes: 2007 and 2009
- 1.6.1 ‘Spotlights’ and ‘Signposts’
- 2. Inheritance Tax Mitigation: The Basics
- 3. Making Gifts: Outright or Protected?
- 4. Trusts: Tax-Efficient Management
- 6. The Family Business
- 6.1.3 Capital Gains Tax angles
- 6.3.5 Entrepreneurs’ Relief: Furnished Holiday Lettings
- 6.4.1 Summary principles
- 8. Chattels
- 9. Investments
- 11. Pensions
- 11.2.2 Withdrawing benefits
- 11.2.3 Transitional provisions
- 11.2.4 Unregistered schemes
- 11.3.1 The basic rule
- 11.3.2 Tax relief
- 11.3.3 Scheme input periods
- 11.3.4 Occupational schemes
- 11.4.1 SIPPs and SSASs distinguished
- 11.4.3 Transactions with employers
- 11.5.2 Tax-free cash
- 11.5.5 Death benefits
- 11.5.6 Age 75: ASP or annuity purchase?
- 11.5.7 Maximise or minimise income in retirement?
- 12. Charitable Giving
- 15. Leaving the UK
- 15.2.1 Overview
- 15.2.4 Occasional residence abroad not enough
- 15.2.5 Full-time work abroad
- 15.2.6 Ordinary residence
- 16. Non-UK Domiciliaries Living in the UK
- 17. Offshore Trusts and Companies
- 18. Wills
- 20. Compliance
2 - Inheritance Tax Mitigation: The Basics
Chapter: 2 - Inheritance Tax Mitigation: The Basics
Gifts of shares to employee trusts
2.2.9
To secure the IHT exemption, the beneficiaries of the trust are restricted to a class defined by particular employment or type of employment and their relatives (IHTA 1984 s28, with the conditions set out in s86). Where there is a particular employment, the class must comprise all or most of the employees or the trust must be an approved profit-sharing scheme. Trustees must hold at least 50% of the company and no participator (broadly a shareholder with 5% or more) must be able to benefit.