Tech talk

Trusts & Inheritance Tax Changes - Finance Act 2006 - Final Position - TT27/06

This Tech Talk summarises the final position with regard to the changes to the Inheritance Tax (IHT) treatment of trusts made in the Finance Act 2006. Details of the original Budget proposals and subsequent amendments were included in Tech Talks 16,17,18,25 & 26. This Tech Talk gives a complete summary of the points included in these bulletins now that the Finance Act 2006 has received Royal Assent (on 19 July 2006). The final legislation for the IHT changes is contained in Section 157 and Schedule 20 of the Act.

The aim of this bulletin is to highlight the changes and explain how they impact on the trusts offered for both protection and investment products as well as looking at some of the issues for will planning.

Re-cap
Prior to 22 March 2006, any lifetime gift to an Interest in Possession (IIP) trust or an Accumulation & Maintenance (A&M) trust would have been treated as a Potentially Exempt Transfer (PET). Any beneficiary with an interest in possession (i.e. entitlement to income under the trust), would have the value (or a share of it) as part of their own estate for IHT purposes. This was a special treatment which meant that these trusts were not subject to the mainstream IHT regime for trusts. In practice, only discretionary trusts were subject to this regime, otherwise known as the "relevant property" regime.

Under the proposals in the Budget, most trusts created on or after 22 March 2006 will now be subject to the "relevant property regime". The IHT treatment for trusts is therefore being streamlined so that all trusts are treated in the same way with some limited exceptions.

What does this mean in practice?

This means that:

  • When a trust is created, there will be an immediate charge to IHT at 20% on lifetime transfers that exceed the available IHT threshold (£285,000 for the tax year 2006/07).
  • a periodic charge (a maximum of 6%) will apply at every 10th anniversary on the value of the trust assets over the nil rate band at the time. Chargeable transfers made by the settlor in the seven years prior to creation of the trust must be added to the value of the trust fund for this purposes.
  • An exit charge will apply where capital is distributed to beneficiaries between 10 year anniversaries. This is known as the "proportionate" charge since it is calculated by reference to the periodic charge.

Does this mean that PETs have gone altogether?

PETs can still be made if the lifetime gift is made outright to another individual. If the gift is being made to a trust after 22 March 2006, it will still be treated as a PET if the trust is an Absolute or Bare Trust or a trust for a disabled person (as defined under section 89(4) IHTA 1984).

PETs made to IIP and A&M trusts prior to 22 March 2006 would have been PETs at the time the gift was made and these will not be affected retrospectively.

Can existing trusts in place at 22 March 2006 be affected at all?

Yes. Although as detailed above, earlier gifts to the trust will not be affected by the change, in certain circumstances the trust could fall into the new regime. Before we look at the details on this, the first point to consider is whether the trust was actually in place before 22 March. For the trust to be "created", the asset must have been transferred to the legal ownership of the trustees. In the case of cash, or a life assurance policy, the cheque must have been encashed. Simply dating the trust prior to 22 March is not sufficient.

Any additional gifts made to an existing trust arrangement will be subject to the new regime.

Existing Interest in Possession Trusts

Interest in possession trusts which were in place prior to 22 March 2006 will not suffer any exit or periodic charges unless the existing interest comes to an end. Under the new rules, any interest in place at 22 March 2006 is known as a "prior interest". If this interest ends on the death of the beneficiary, the value of the trust will be part of the beneficiary's estate for IHT purposes. If the interest comes to an end because the beneficiary (or any other beneficiary) becomes absolutely entitled to the assets, no exit charge will apply. If the assets continue to be held on trust after the death of the original beneficiary with the prior interest and another beneficiary becomes entitled to an interest in possession, the old regime will continue to apply i.e. the value of the trust fund will be deemed to be part of the beneficiary's estate for IHT purposes and the trust will not be subject to the new regime. This new interest is known as a Transitional Serial Interest (TSI) as it is treated as having been in place as at 22 March 2006. This is a relaxation of the original Budget proposals which previous indicated that the beneficiary would have had to die before 6 April 2008 for this to apply.

If the interest ends after 6 April 2008 during the lifetime of a beneficiary with a prior interest and the asset stays in trust, for example where trustees of a flexible trust alter the beneficiary of the trust, this will be regarded as a new trust for the purposes of the new regime and exit and periodic charges will apply thereafter. The beneficiary being removed will be deemed to have made a chargeable lifetime transfer.

The period from 22 March 2006 to 6 April 2008 is therefore a transitional period in which trustees have the opportunity to vary the original beneficiary without bringing the trust into the new regime. Any new interests created during this window of opportunity will also be TSIs. Trustees would therefore be well advised to review any flexible trusts in place at 22 March 2006 before 6 April 2008 to ensure the default / named beneficiaries are still appropriate.

Another change under the new rules relates to the gift with reservation of benefit provisions. Take the example of a flexible trust where the children are "default" (or named) beneficiaries. In the past their interest could be terminated (say in order to skip a generation in favour of the grandchildren) and the children could still benefit as discretionary beneficiaries without the Gift with Reservation provisions applying. Now if an interest is terminated and that person is still able to benefit from the trust, this will be treated as a gift with reservation of benefit for the beneficiary being removed. Trustees may then need to consider removing that beneficiary from the classes of potential beneficiaries.

Existing Accumulation & Maintenance Trusts In the past, Accumulation & Maintenance trusts have been popular where clients wish to provide funds for children or grandchildren and are often used in conjunction with funding for school or university fees. Typically this kind of trust would give beneficiaries an income entitlement at age 21 or 25 and capital would often be deferred until some point in the future.

Under the original Budget proposals such trusts would only remain outside of the new regime if the trust terms state (or were amended to state) that beneficiaries would become absolutely entitled to trust assets at age 18. This caused an uproar since many parents were reluctant to give their children or grandchildren large sums of money at 18. Consequently, the original proposals were later amended to provide a slightly more relaxed tax regime where the trust allows the beneficiary to take the trust assets absolutely no later than age 25. Broadly, this favoured tax status can be summarised as follows:

  • Trust assets will be exempt from periodic charges while the beneficiary is under 18
  • Periodic charges will then only start to apply if the trust continues beyond age 18
  • If the trust continues for a maximum 7 more years to age 25, then the capital leaving the trust will be subject to 7 years worth of charge on exit , i.e. 7/10 x 6% = 4.2% max
  • If a beneficiary became absolutely entitled at (say) age 20, then the maximum exit charge would be 2/10 x 6% = 1.2%


Existing A & M Trusts can be modified before 6 April 2008 to reflect the 18 - 25 provisions. Assuming this is the case, then when a beneficiary is under 18 at the end of the transitional period on 6 April 2008, the 6% regime will not apply until the beneficiary attains age 18. These provisions can also apply to will trusts (Trusts for bereaved minors) - more of this later.

In practice, what will the consequences be for lifetime IHT planning?

Given that most lifetime gifts for small to medium sized estates fall within the nil rate band, in practice lifetime IHT planning using trusts can still be carried out in many cases without an immediate IHT charge of 20% arising. Provided the donor survives for seven years, the full nil rate band will be available again. On the face of it this does not appear to be much different from a PET, however chargeable lifetime transfers can in practice affect the tax payable on gifts over a 14 year period prior to death. A detailed example of this was included with TT18/06.

In order to avoid this complication, one planning strategy would be for clients to make a lifetime gift up to the value of the nil rate band every seven years and any gifts in between should be simply to use exemptions such as the annual exemption or normal expenditure out of income exemption

Impact of the new regime on writing protection policies in trust Life assurance protection policies written under flexible trusts prior to 22 March 2006 will not be subject to the new regime even though premiums will continue to be paid on the policy after this date. The reasoning behind this is that the premiums payable are simply fulfilling a contractual obligation rather than constituting new assets to existing trusts. The new legislation also makes it clear that where policy terms are varied on or after 22 March, the trust will still be protected from falling into the new regime provided that the original terms of the policy allowed for this. The amended legislation refers to this as an "allowed variation" defined as "…a variation that takes place by operation of, or as a result of exercise of rights conferred by, provisions forming part of the contract immediately before 22 March 2006".

Changing the beneficiaries on an existing flexible trust after 6 April 2008 (other than as a result of the death of the default / named beneficiary) will bring the trust into the new regime as noted earlier in this bulletin.

Life policies written into trust after Budget Day will however be within the new regime. We will now examine in detail how the provisions will impact.

On creation

In general, where a trust is created by a regular premium life policy, there will be no 20% lifetime tax charge since the value of the gift made is simply the premiums paid on the policy. Such premiums are usually exempt from IHT either because they fall within the annual exemption (currently £3,000 per annum) or because the premiums qualify as normal expenditure out of income based on the proposer's spendable income.

Even where large premiums are paid and none of the exemptions apply, provided the policy owner has not used his/her nil rate band, no tax charge should arise provided that the premiums over a seven year period do not exceed the available nil rate band.

Where an existing policy is placed into trust now the value of the gift is the open market value of the policy (usually this is the greater of the surrender value or the premiums paid to date). Again provided this is within the available nil rate band, no tax charge will arise.

Ongoing periodic & exit charges

Periodic and exit charges apply where there is a value within the trust. Consequently as long as the life assured is in good health, or the policy has no significant surrender value, there will be no value in the trust, therefore no charges will arise. HMRC have confirmed that they do not expect individuals to have medicals every 10 years for the purposes of the new legislation. Provided the individual is not seriously ill to the best of their knowledge and belief, no further action would be needed. They also indicated that for the purposes of the 10 yearly charge, generally they will accept the surrender value of the policy.

If however the surrender value is significant or the life assured is in poor health, the value of the trust at the 10th anniversary (and each subsequent 10th anniversary) may be subject to IHT at 6% on the excess above the nil rate band at that time.

More commonly charges may arise if a claim is made on policy and the proceeds remain in the trust for a period of time. An exit charge should not arise where proceeds are paid out within the first ten years if the value of the initial gift (including the cumulative total of the settlor's chargeable transfers in the seven years prior to the gift) plus any added property is below the nil rate band. If funds continue to be held in trust beyond the tenth anniversary any exit charges will depend on the rate of the previous periodic charge.

Example

It is August 2006 David and Sally do not want to make any lifetime gifts. Instead they take out a joint life second death policy with a sum assured of £400,000 which is intended to meet the IHT liability on their estate and they write this in a flexible trust for the benefit of their three children. The monthly premiums qualify as normal expenditure out of income and therefore no immediate IHT charge will arise on setting up the trust. Assuming the second death arises 15 years later the IHT implications for the trust will be as follows:

August 2016No periodic charge assuming the surrender value is
(Year 10)             below the nil rate band at the time.

2nd Death          Claim is made. If funds are paid out immediately no IHT implications.
(Year 10)            If held in trust beyond the following 10th anniversary - IHT
charge possible. 6% x (value of trust less NRB)

In the vast majority of cases, no IHT liabilities will arise in connection with life policies in trust.

Business Protection Policies

Although, in theory business trusts are also affected, in practice IHT charges would be unlikely to arise. Payment of the premiums are not treated as gifts since they are in connection with a commercial arrangement. In the event of a death claim the funds would normally be paid immediately to the other shareholder in order that they can purchase the shares of the deceased.

In the event of a critical illness the shareholder could of course choose not to sell his/her shares in which case if the proceeds remain in trust beyond the 10th anniversary of the trust's creation, periodic and exit charges could arise. The solution would be to release the funds from the trust and for the other shareholders to hold on to the cash personally.

Implications for our trust range for bonds

We offer a range of trusts for use with investment bonds. We can comment on the implications for both new and existing trusts as follows:

Estate Planning Trust (Discounted Gift Trust)

Trusts set up on or after 22 March 2006:

If the trust is set up for a disabled person or as a bare trust then the previous rules still apply.

If the trust is not set up for a disabled person or as a bare trust, then the discount will still apply but the discounted gift will not be a PET as before but rather a chargeable lifetime transfer. If the value of this when added to the settlor's chargeable cumulative total is within the Nil Rate Band then no lifetime charge to IHT will arise. If however the Nil Rate Band is breached then the excess will be subject to an entry charge at 20%.

If a beneficiary dies, then his/her interest under the trust will not form part of that person's estate for IHT purposes (as it would have done previously). Similarly, if the beneficiaries are changed then this will not now be regarded as a PET by the "outgoing" beneficiary on the value of their interest under the trust.

Completion of form IHT100 is necessary for a settlor to inform HMRC regarding gifts which give rise to an immediate charge to IHT. This is required within one year of making the gift (it is not necessary to inform HMRC of PETs when they are made). Form IHT100 is only not required when the value of the gift plus other chargeable transfers in the same tax year do not exceed £10,000 and the gift and other chargeable transfers made by the individual in the previous ten years does not exceed £40,000.

The fact that a discount is merely suggested and not cast in stone therefore opens up the possibility of either the IHT100 form being completed with an incorrect valuation or IHT being underpaid when the chargeable transfer turns out to exceed the Nil Rate Band due to the discount being wrongly overstated. However the good news is that HMRC will now have to agree the value of the discount when the trust is created as opposed to when the settlor dies.

As noted earlier in this bulletin, the value of any property included in the trust at the tenth anniversary will be subject to a periodic charge. Under a discounted gift trust, the settlor retains the right to certain capital payments assuming he survives to specified dates in the future. Since these rights are held on bare trust for the settlor, HMRC have confirmed that the value of these rights are not part of the trust property for the purpose of the ten yearly charge. So the relevant property in the trust will be the value of the bond less the value of the settlor's rights. Furthermore, strictly speaking, these rights would need to be revalued every ten years and underwritten at that time. However, HMRC have also confirmed that it will be acceptable simply to add ten years to the settlor's age at outset for this purpose provided that the discounted gift trust was underwritten when the trust was established.

Since the settlor's rights do not form part of the trust property, it has also been confirmed by HMRC that exit charges will not apply when the settlor receives his/her income.

Existing Estate Planning Trusts (and existing SMI IHT Plan trusts)

The discounted PET previously made will be unaffected (though any addition of new assets will be subject to the new rules). If the beneficiary with the interest at 22 March 2006 dies ("the prior interest"), their interest under the trust will form part of their estate for IHT purposes. A new beneficiary can be appointed after the death of the beneficiary with the "prior interest" without bringing the trust into the new regime.

If the named beneficiaries are changed during their lifetime, then this will be regarded as a PET by the "outgoing" beneficiary on the value of their interest under the trust if the change occurs before 6 April 2008. The new beneficiary will then have the value as part of their own estate. If the change occurs on or after this date, the outgoing beneficiary will make a chargeable lifetime transfer and the trust will be subject to the new regime from then on.

The other trusts that we currently offer for investment bonds are as follows: -

Gift trusts (flexible and absolute)

Family Inheritance Trust
Gift & Loan Trust Probate Trust
Probate Trust

Trusts involving a gift

It is only the Gift Trusts and the Family Inheritance Trust which involve the creation of a PET. Since the Absolute Gift Trust gives an absolute entitlement to income and capital, this falls outside the new regime ie gifts to these trusts will continue to be PETs. For Flexible Gift Trusts and Family Inheritance Trusts established on or after 22 March 2006 the gift (or the Gifted Fund in the case of the Family Inheritance Trust) will constitute a chargeable lifetime transfer with IHT at 20% payable on gifts in excess of the Nil Rate Band. Thereafter periodic and exit charges will apply as appropriate. (No periodic or exit charges will apply to the Reserved Fund in the Family Inheritance Trust since this is held on bare trust for the settlor). As detailed earlier, the trust fund will not form part of any beneficiary's estate as would have happened previously. The value of the initial transfer should be known with accuracy allowing for correct completion of form IHT100.

For those Flexible Gift Trusts & Family Inheritance Trusts already in existence then they will remain unaffected providing no new additions to the trust are made or no change in the existing beneficiary's lifetime occurs after 6 April 2008 as detailed earlier.

Gift & Loan Trust

The "Gift & Loan" trust which we offer is in fact purely a loan arrangement with no gift now involved. Therefore, no PET was made previously. On the basis therefore that no initial transfer of value is included, this trust will be affected to a much lesser extent by the new regime. However , the beneficiaries will no longer have the growth as part of their estates for IHT purposes, therefore the trust could be subject to periodic and exit charges at some point in the future depending on the value of the trust fund. HMRC have confirmed that for the purposes of calculating the periodic charge, the value of the outstanding loan balance repayable to the settlor can be deducted from the value of the trust property. There would therefore need to be significant growth (in excess of the nil rate band in the trust assuming no earlier transfers were made by the settlor prior to creating the trust) before any periodic charges would apply.

Existing Gift & Loan Trusts will only become subject to the new regime if beneficiaries are changed during their lifetime after 6 April 2008 as covered earlier.

Probate Trust

The probate trust is designed avoid probate (Confirmation in Scotland) on the death of the life assured. It is commonly used with offshore bonds in order to speed up the claims process and avoid the administrative burden of obtaining probate in another territory. This trust is a flexible trust where the settlor is automatically included as a potential beneficiary to allow access. The trust is not offered for IHT planning purposes since the assignment of a policy to such a trust would normally be seen as a gift with reservation therefore it would continue to be part of the settlor's estate. Unfortunately, this trust appears to be a casualty of the new regime since although it is a gift with reservation, the transfer to this trust is nevertheless a chargeable lifetime transfer. Therefore depending on the value of the asset going into trust, an immediate tax liability could arise on creation without it escaping IHT on the settlor's death. The trust would also be subject to ongoing periodic & exit charges again depending on the value. So it would appear unlikely that this trust will be used in the future in its current form. We are currently looking at ways to amend this trust to make it more tax efficient under the new regime.

Spousal By Pass Trust (For use with Pension Arrangements)

We also offer a Spousal By Pass trust for use with certain pension arrangements. Since this trust is a discretionary trust, this already came within the "relevant property regime" and therefore there are no changes to the tax implications of using this trust as a result of the Finance Act. Full details of the tax treatment of this trust are available in the technical note to the Spousal By Pass Trust which can be found on our website.

How are will trusts affected?

Many trusts created in clients' wills are discretionary trusts anyway (e.g. nil rate tax planning trusts). Since discretionary trusts have always been subject to the "relevant property regime" nothing has changed.

However, it is still recommended that clients' wills should be reviewed to ensure that any trusts created are still appropriate in particular, any trusts for the benefit of the spouse or young children.

Trusts for Surviving Spouses

The Finance Bill introduced the concept of an "Immediate post-death interest" (IPDI).

For deaths on or after 22 March 2006, a will trust (or one arising under intestacy) is subject to the discretionary trust regime unless an IPDI is created. Broadly this required an interest to arise immediately on death:

  • Which could only be terminated in the life tenants favour or with their consent
  • Which will end with the trust property passing into absolute ownership, or onto trusts for a minor child, a disabled person or charity

Under the original proposals therefore a very simple will trust with income payable to surviving spouse/civil partner for life and remainder to children absolutely would qualify as an IPDI (and avoid the discretionary trust charges). If however the remainder interest continued in trust for children (rather than passing to them absolutely on death of the life tenant), then it would not qualify. Similarly, the existence of a standard power of appointment exercisable by the trustees in favour of a range of beneficiaries also breached the qualifying condition.

To appreciate why it is desirable to create an IPDI, consider a will trust creating an IPDI with the life tenant being surviving spouse/civil partner. If so, the gift into trust on death qualifies for the IHT inter spouse exemption. If however the trust does not qualify as an IPDI then it would be taxed as a discretionary trust with no inter-spouse exemption available. This posed a major problem since many wills had already been drafted comprising a nil rate band discretionary trust, and residue then passing into a flexible interest in possession (IIP) trust in favour of surviving spouse/civil partner. The aim of these wills was clearly to avoid an IHT liability on first death, yet if the Budget proposals had been enacted as they stood, an IHT liability would have arisen on estates above the nil rate band.

The requirement for there to be an absolute interest following the life tenant's death was dropped as the bill progressed through Parliament. It is no longer necessary for the life tenant to consent to their interest being ended. Therefore, a flexible will trust with surviving spouse/civil partner being the life tenant, but with powers for the trustees to appoint to a range of beneficiaries (e.g. children, grandchildren) will qualify as an IPDI, and therefore enjoy the benefit of the inter-spouse exemption at time of first death.

S144 IHTA 1984 (Discretionary Wills)

Many individuals when drafting wills are unsure how their estate should be distributed on their death. If so, a common solution is to leave the estate (or part of it) to be held on discretionary trust. S144 allows distributions to be made from discretionary trusts within two years of death as if the gifts had been made by the deceased, and crucially without any charge to IHT (as there would normally be for property leaving a discretionary trust). The trustees therefore could, within this two year period, distribute assets or declare further trusts as they see appropriate, or perhaps act in accordance with a letter of wishes drafted by the deceased. Under original proposals, if S144 was used to create a life interest for surviving spouse then this did not constitute an IPDI (since it did not arise immediately on death). Consequently the inter spouse exemption would not be available. However, under the amended provisions if S144 is being used, trustees can create a Bereaved Minor trust (see below), an 18-25 trust, or an IPDI as if they had been created in the will. If the IPDI is in favour of the spouse, the spouse exemption will be available.

Trusts for Bereaved Minors

Trusts for children should also be reviewed if the existing will includes provisions for income or capital to be withheld beyond age 18. The original Finance Bill proposals stated that from 22 March 2006, a trust created on death by a parent for a minor child would fall into the mainstream discretionary trust ('relevant property') regime unless the child became fully entitled to the trust assets at age 18. In other words if the child was not to become fully entitled by age 18 (and assuming the child was not disabled) then the trust would be subject to periodic and exit charges from the date of death of the parent. Accordingly, the tax favoured rules for Bereaved Minor trusts were only available in very restrictive cases. Fortunately, the Government has given into pressure on this issue and favoured trust status can now apply to trusts continuing beyond age 18, so long as the beneficiary will take the trust assets absolutely no later than age 25. Assuming this is the case then : ·

  • Trust assets will be exempt from periodic charges while the beneficiary is under 18
  • Periodic charges will then only start to apply if trust continues beyond age 18
  • If trust continues for a maximum 7 more years to age 25, then the capital leaving the trust will be subject to 7 years worth of charge on exit , i.e. 7/10 x 6% = 4.2% max
  • If beneficiary became absolutely entitled at (say) age 20, then the maximum exit charge would be 2/10 x 6% = 1.2%

If however the will trust is fully flexible with no certainty as to when the child will receive his/her share, then the discretionary trust regime (i.e. the 6% regime) will apply from date of death.

We have already looked at ways in which existing A & M trusts can be amended to fall within this new category of trust and receive favoured tax status.

IOU Schemes (Designed to use the nil band with the family home)

One piece of good news with regard to will planning is that nil rate tax planning with the family home may become simpler. In the past the difficulty with leaving a half share in the family home to discretionary trust was to ensure that the spouse was not deemed to have an interest in possession in the trust by having a right to live there. In this case the value of the trust fund would be deemed to have been part of the spouse's estate. To combat this, various schemes based on an IOU or charge were developed. However, it may be the case that since having an interest in possession in a flexible or discretionary trust no longer means that the value is included in the beneficiary's estate under the new rules, presumably these schemes will become less popular particularly if the value of the share of the house is within the nil rate band (unless the interest is deemed to be an IPDI). We can expect more comment on this over the coming months however in the meantime it may be safer to continue to use IOU or charge schemes until such time as this has been clarified. The IOU or charge scheme may be particularly beneficial if the value of the half share of the house is in excess of the nil rate band anyway.

Comment

Although there is no doubt that the changes made in the Finance Act 2006 have made trusts more complex, the impact of the new regime will be far less dramatic than first thought. The Government estimate that additional IHT of approximately £15M per annum will be raised from these measures which emphasises how few people will actually be affected. Given that most life policies and lump sum gifts within the nil rate band will largely be unaffected, the extra tax raised will mainly come from large lump sum gifts in excess of the nil rate band being placed into trust. Clients with large estates may well decide to use absolute or bare trusts for their lifetime IHT planning although it must always be remembered that this lacks flexibility.

In terms of opportunities for financial advisers, the changes will offer the possibility of strengthening professional connections by reviewing existing wills & trust arrangements prior to 6 April 2008 to establish whether any amendments are needed. This will inevitably involve the clients' solicitors. Clients will also need to think about their estate planning strategies earlier in their lives than before if they have larger estates to ensure that they can use their available nil rate bands every seven years. It is anticipated that there will be greater demand for discounted gift trusts where clients can make gifts in excess of the nil rate band without any immediate IHT liability after taking account of the discount. Finally, rather than incurring an immediate IHT charge at 20%, many clients contemplating large gifts may well choose to fund a whole of life policy instead.

So without a doubt clients will still need advice on trust based IHT planning solutions more than ever before.

Liz Henderson -  August 2006


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