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Inheritance tax problems in Finance Bill 2020

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The rules on excluded property trusts are due to change with effect from royal assent. These changes are complex, and the new rules can have an unexpected and retroactive effect where a settlor has added to an excluded property settlement after becoming deemed domiciled, or transfers of property have been made between trusts (without any settlor consent or involvement) after the settlor became deemed domiciled. Trustees should check what transfers and additions have been made in the past and the status of the settlor at each transfer or addition. It may be necessary to exclude the settlor going forward as a beneficiary, ideally before royal assent.

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