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MATTHEW HUTTON considers FA 2006, Sch 20. What should be done with trust structures in place on 22 March 2006?
KEY POINTS
- HMRC's clarification of the new trust regime
- The capital gains tax and inheritance tax implications of A & M trusts
- Exit charge calculations
- Practical implications of the rule changes
- Excluded property settlements
As we are about three-quarters of the way through the 'transitional period' which began on 22 March 2006 and which will end (largely) on 6 April 2008 now seems a good time to stand back and survey the scene following the FA 2006 'alignment' of the inheritance tax regime for trusts. In analysing the legislation we have the benefit of:
(a) HMRC's answers to the 43 questions originally put to them in September 2006 by STEP and CIOT and most recently revised in early April 2007 (http://snipurl.com/1osal);
(b) HMRC's answers to the seven further questions put to them in...
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