Inheritance Tax: Residence Nil-Rate Band Planning

Introduction ‘FAs 2015 and 2016 have introduced a residence nil-rate band which enormously complicates the drafting of wills…’ ‘Drafting Trusts And Will Trusts – A Modern Approach’, by James Kessler QC & Charlotte Ford (13th Edition) (December 2016) (‘Kessler’). ‘Although the intention is to ensure that the house can be passed on death with the benefit of the additional nil rate band, this is not how the rules work. The extra nil rate band is set off against the chargeable estate and so reduces the total tax bill charged on that estate. But, of course, there may still be tax payable and it may still be necessary therefore to sell the house to pay the bill!’ ‘The residence nil rate band – som

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