My question is in respect of the pre-owned assets tax (POAT). My client is a widow, who is the life tenant of an immediate post-death interest (IPDI) (see IHTA 1984, s 49A) created by her late husband's will. She did not require all the income to which she was entitled and encouraged the trustees to appoint 30% of the trust fund, represented by a holiday home at the seaside, absolutely to her son.
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