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The Schedule 20 changes - some practical questions and answers

Category Technical Articles
AuthorTechnical Department
Article by Emma Chamberlain, Chairman, CIOT Capital Taxes sub-committee, and Chris Whitehouse - joint authors, 'Trust Taxation: Planning after the Finance Act 2006'. This article appeared in the January 2007 issue of Tax Adviser.
Inevitably a number of queries have arisen on the interpretation of the inheritance tax legislation introduced in FA 2006. STEP and the CIOT submitted a list of questions to HMRC on 7 September 2006 and received a helpful reply on 3 November. Those questions and answers are published on the websites of both bodies: go to:;n=385. The authors intend to look here at part of that correspondence, and consider the impact of the new legislation in relation to one area - namely transitional serial interests of pre-22 March 2006 interest in possession trusts. They do not consider the special regime that applies for life insurance policies.

January 2007 by Emma Chamberlain and Chris Whitehouse

Technical Department
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