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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: http://www.tax.org.uk/showarticle.pl?id=4761;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
020 7235 9381

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