Has a shareholder acquired control of a company through his role as a trustee?
In 2004 our married clients Mr and Mrs B created four trusts two each. The family trading business which is valued at £48m is owned as follows: Mr B 25%; Mrs B 24%; Mr B trust 1 2%; Mrs B trust 1 2%; Mr B trust 2 23%; and Mrs B trust 2 24%.
This year we have been asked to prepare the 10-year anniversary inheritance tax returns for the trusts.
The four trusts have two independent trustees and a third trustee who is the spouse of the settlor; that is to say the two trusts settled by Mr B have Mrs B as the third trustee...