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A couple both now deceased set up a trust using a standard discretionary trust deed from the company with which they had invested some money in an onshore insurance bond.
The bond was one that terminated on the death of the second to die which occurred when the wife died this year. The husband had died four years before.
My interpretation of the tax position is that one half of the chargeable event gain will be taxed on the wife (as settlor of her trust) and the other in the hands of the trustees (of the husband’s trust). This will give the husband’s trust a fairly large tax liability and after crediting the notional basic rate tax the larger part of this tax liability goes into the ‘tax pool’.
However given that the proceeds of the chargeable event gain are the sole asset of...
