- 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
A convenient recipient of lifetime gifts
2.3.1
Where a gift is to be made but either the donor wishes to ensure some protection and/or a suitable donee does not present himself, a trust can be a useful mechanism. Even if death follows within seven years, the value charged to IHT will be that prevailing at the date of the gift, not at the date of death, by when the asset(s) may have appreciated. The full range of exemptions and reliefs is available for transfers into trust as for other types of property. Note that, on termination of a qualifying or ‘estate’ interest in possession, use of the life tenant’s annual exemption(s) requires notice by the life tenant to the trustees (IHTA 1984 s57). The same point applies to the life tenant’s marriage exemption.