Private client section

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Issue 23 – November 2007

Contents

Cases
Features
Articles

News

Events

Discounts (how to book and claim discounts)

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Cases

1. Caton v Goddard and another

Citation: [2007] All ER (D) 370 (October)
Court: Chancery Division
Judge: Briggs J
Hearing date: 24 October 2007
Summary: will – testator – soundness of mind – medical evidence concluding testatrix lacking testamentary capacity – whether testatrix having capacity – whether probate of will should be set aside.

The 88-year-old testatrix was admitted to hospital in 1998. The first defendant was a solicitor who was contacted by the second defendant, on behalf of the testatrix, in order to draft a will. The first defendant attended the testatrix and satisfied himself that she had the requisite testamentary capacity. Under the will, the second defendant received the major interest while the claimant, the testatrix's son, received nothing. The testatrix died in March 1998, and subsequent evidence came to light concerning her mental state. A joint medical expert was instructed, and he concluded that, on the balance of probabilities, the testatrix lacked the required mental capacity. The claimant sought revocation of the probate. The first defendant indicated that he would not defend the claim and the second defendant died prior to the trial of the claim.

The claim would be allowed.

In balancing the evidence of the first defendant and the medical expert, the court was satisfied that the first defendant had been deceived as to the mental state of the testatrix. The evidence of the medical expert that the testatrix, on the balance of probabilities, lacked testamentary capacity was to be preferred.

The claimant was entitled to have probate of the will set aside.
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2. Negus v Bahouse and another

Citation: [2007] All ER (D) 353 (October)
Court: Chancery Division
Judge: Judge Roger Kaye QC sitting as a judge of the High Court
Hearing date: 23 October 2007
Summary: administration of estates – family provision – application

The deceased hanged himself in March 2005. He had two former wives, a son and daughter from his first marriage, and had been cohabiting with N at the property he owned since 1997. Pursuant to a 1996 will, the deceased's son was the majority beneficiary of his £2.2 million estate. No provision was made for N in the 1996 will. Probate was granted to the defendant's son and first wife. They issued possession proceedings in respect of the property. Subsequently, N cross-applied for a declaration that she had a beneficial interest in the property and/or sought reasonable financial provision for her future pursuant to section 2 of the Inheritance (Provisions for Family and Dependants) Act 1975, having come within section 1(1B) of the Act. Section 1(1B) of the 1975 Act applied to a person if for the whole of the period of two years ending immediately before the date when the deceased died was a person who lived in the same household as the deceased as the deceased's civil partner. In her evidence, N stated that she had given up work to become a housewife for the deceased, and they had plans to marry. She also stated that the deceased repeatedly commented that she would have a roof over her head and that she would be taken care of.

The court ruled: Even allowing for the equivocal statements made by the deceased in relation to the property, the court could not, on the evidence spell out a specific agreement that would grant N a beneficial interest in the property. On the facts, however, N fell within the provisions of section 1(1B) of the 1975 Act, and was entitled to reasonable financial provision to be made for her.

In the circumstances of the instant case, a reasonable financial provision for N's lifetime would be the transfer of the property to her, without the encumbrance of mortgage, and the payment of £240,000. The possession claim would be dismissed.
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3. Cowan v Eisler and another

Citation: [2007] All ER (D) 327 (October)
Court: Chancery Division
Judge: Judge Roger Kaye QC sitting as a judge of the High Court
Hearing date: 22 October 2007
Summary: sill – codicil – reviving revoked will – construction – whether codicil having effect of reviving will

The claimant was the testatrix's son and was named as her executor under her 1991 will. The first defendant was named as the testatrix's sole executor under her 2002 will. The second defendant was a beneficiary under both wills, but was bequeathed a greater share under the 2002 will. The claimant relied on two codicils, made in 2003 and 2005, in support of his application for probate to be granted in respect of the earlier will. He contended that the codicils incorporated the 1991 will, specifically by the codicils mentioning the 1991 will and confirming it. The defendants challenged the validity of the 2003 and 2005 codicils and claimed that there had been no intention to revive the 1991 will in the subsequent codicils.

The court ruled: On the evidence there could be no dispute that it was the testatrix's intention to revive the earlier will. Further, on the true construction of the codicils, the effect of their terms was to incorporate the 1991 will.

Probate would be granted to the 1991 will, and the 2003 and 2005 codicils.

Re Pearson, Rowling v Crowther [1963] 3 All ER 763 applied.
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4. Smith and others v Revenue and Customs Commissioners

Citation: [2007] All ER (D) 206 (October)
Court: Chancery Division
Judge: Lightman J
Hearing date: 16 October 2007
Summary: inheritance tax – annuity purchased in conjunction with life policy – associated operations

Section 263 of the Inheritance Tax Act 1984, so far as material, provides: “(1) Where … (a) a policy of life insurance is issued in respect of an insurance made after 26th March 1974 or is after that date varied or substituted for an earlier policy, and … (b) at the time the insurance is made or at any earlier or later date an annuity on the life of the insured is purchased, and … (c) the benefit of the policy is vested in a person other than the person who purchased the annuity … then, unless it is shown that the purchase of the annuity and the making of the insurance (or, as the case may be, the substitution or variation) were not associated operations, the person who purchased the annuity shall be treated as having made a transfer of value by a disposition made at the time the benefit of the policy became so vested … “

Section 268 of the Inheritance Tax Act 1984, so far as material, provides: “(1) In the Act ‘associated operations’ means, subject to subsection (2) below, any two or more operations of any kind, being … (b) any two operations of which one is effected with reference to the other, or with a view to enabling the other to be effected or facilitating its being effected … “

The first, second and third appellants were the children of Sir John and Lady Smith. The fourth appellant was a co-executor of Sir John's estate. In October 1996, Sir John and Lady Smith took out three annuities and three policies of life assurance (the plan). The stated objective of the plan was to “achieve capital growth over a selected number of years in a sound and tax efficient way from the investment of a lump sum”. The “proposal” (effectively the application form) for the plan identified Sir John and Lady Smith as the lives assured and contained details of the annuity that they were purchasing and of the proposed assurance policy. A medical evidence questionnaire was completed by each of them. Prior to issuing the annuities, the insurer required Sir John to undergo a medical examination with his GP. The policies were issued on 8 November 1996, and the benefits of the policies were vested in the first to third appellants. Both Sir John and Lady Smith died within seven years of the issue of the policies. Subsequently, the Revenue's Special Commissioner determined that the purchase of the three annuities and the vesting of them in the first to third appellants fell to be treated as a transfer for value for inheritance tax purposes, on the basis, inter alia, that they were associated operations within the meaning of section 263 of the Inheritance Act 1984. Before the Special Commissioner, the Revenue's statement of practice E4 (the practice statement), relating to how section 263 of the 1984 Act was to be interpreted, fell to be construed. The practice statement, so far as material, provided: “Life assurance policies and annuities are regarded as not being affected by the associated operations rule if … first, the policy was issued on full medical evidence of the assured's health and … second, it would have been issued on the same terms if the annuity had not been bought.” The Special Commissioner held, inter alia, that the “full” medical evidence had not been provided and that the purchase of the annuities and the life assurance had therefore been associated operations. The appellants challenged that decision.

The primary issue that fell to be determined was whether the Special Commissioner had erred in law in holding that “full” medical evidence referred to medical evidence over and above the information provided in answer to the insurer's medical questionnaire, having regard to the definition of 'associated operation' contained in s 268 of the 1984 Act.

The appeal would be dismissed.

The evident objective of the practice statement was to provide an effective means of protecting the Revenue from efforts made to avoid inheritance tax by means of associated transactions in the form of life assurance policies and annuities. That was achieved by requiring that the life policy had to have been issued on the basis of the provision to the insurer of full medical evidence of the assured's health. It was not sufficient that it was issued on the basis of a health questionnaire issued by the insurer.

The contention to the contrary was not maintainable for two reasons, firstly because the criterion for non-disclosure was the safe-guarding not of the interests of the insurance company, but of the Revenue; and, secondly, because the language used went beyond what the insurance company required, it stressed the need for “full” medical evidence.

Accordingly, the Special Commissioner had plainly been entitled to hold that the answers to the insurer's questionnaire had not constituted the provision of “full” medical evidence. Those answers might have provided sufficient medical evidence to the insurance company for its own purposes, being the sale of the policy and the annuity, but it was not sufficient for the purpose of protecting the Revenue. In those circumstances, he had been practically bound to reach that conclusion.
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5. Kostic v Chaplin and others

Citation: [2007] All ER (D) 203 (October)
Court: Chancery Division
Judge: Henderson J
Hearing date: 15 October 2007
Summary: will – testator – soundness of mind – testamentary capacity

The claimant was the only son of the testator. In two wills that the testator created before his death, dated 1988 and 1989 respectively, he left his entire estate of £8 million to the Conservative Party Association, an unincorporated association, expressing the hope that it would establish a cultural institution to maintain and promote “Christian Democratic values of love, truth and freedom”. Prior to the disputed wills, and pursuant to a 1974 will and subsequent codicil, the sole beneficiary was to be the claimant. It was common ground that from the mid-1980s until the end of his life the testator suffered from a serious and untreated mental illness that manifested itself in delusions involving his wife, mother and sister. The claimant sought a pronouncement against the 1988 and 1989 wills and a pronouncement for the validity of the 1974 will. The first and second defendants were, respectively, the chairman and secretary of the association, who resisted the claim. The third defendant, the Attorney General, sought to establish that the disputed wills created a valid charitable trust.

The issue for determination was whether the testator had testamentary capacity to make the 1988 and 1989 wills, or whether his delusions affected the dispositions made therein.

The claim would be allowed.

In the light of the cumulative weight of the evidence, it was abundantly clear that in 1988 and 1989 the testator had been unable to form a proper appreciation of the claimant's claims upon his estate. His natural affection for the claimant had been poisoned or distorted by his delusions to such an extent that he had been wholly unable to dispose of his property in the way he would have done had he been of sound mind.

The court would, inter alia, pronounce against the 1988 and 1989 wills and grant probate of the 1974 will.

Banks v Goodfellow [1861-73] All ER Rep 47 applied.
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6. Dellar v Zivy and others

Citation: [2007] All ER (D) 121 (October)
Court: Chancery Division
Judge: Kitchin J
Hearing date: 9 October 2007
Summary: conflict of laws – will – construction

The deceased came to England from France in the late 1970s. He owned shares in certain French property holding companies called Societes Civiles Immobilieres (SCIs), namely SCI de la Lisaine and SCI du Castillon. He instructed a partner in a firm of solicitors to draw up his will, which was executed on 15 December 1981. It appointed that partner, subsequently replaced by the claimant, and the deceased's sister, the first defendant, as executors and trustees. It stated the deceased's London address and expressly recorded his domicile as English. By clause 6(a) thereof, the trustees held the residuary estate for the first defendant provided that she survived the deceased by 56 days. By clause 6(b), which was expressed to be subject to clause 6(a), the deceased gave his shares in the two SCIs to the second to fourth defendants and the balance to his godson. By the time of his death, the deceased had disposed of his shares in SCI de la Lisaine but retained his shares in SCI du Castillon. Following his death, those shares remained unsold, but a sale of the company's assets took place, the deceased's share of which amounted to approximately £3 million. The second to fourth defendants alleged that the will did not reflect the provisions, which the deceased had told them would be made for them. They requested information from the deceased's solicitors as to whether there was evidence that he had made a further will. Subsequent to the will's admission to probate, information was provided indicating that that the deceased had stated a wish to alter his will to cut out the first defendant, but that he had taken no action to follow up that wish. The second to fourth defendants brought proceedings in France against the claimant and first defendant, claiming that the shares were the subject matter of a legacy to them. The French court held that it had jurisdiction to hear the matter and the claimant and first defendant appealed against that decision. The claimant applied to the English court for a declaration that the shares passed to the first defendant. Permission was granted to serve the claim on the second to fourth defendants outside the jurisdiction, and it was duly served. The claimant subsequently applied for summary judgment. The French court decided to defer ruling on the appeal until the pronouncement of the decision of the English court concerning the interpretation of the will. The second to fourth defendants filed acknowledgements of service out of time and applied for the claim to be struck out on the basis that England was not the convenient forum for it to be heard. They further applied to set aside the permission which had been granted for service of the claim outside the jurisdiction.

In considering whether the claimant was entitled to summary judgment, an issue arose, inter alia, as to which law should apply to the interpretation of the will.

The claimant submitted that the nature of the will and the circumstances in which it had been executed made it clear that the deceased had intended its interpretation to be decided according to English law, irrespective of what his domicile might have been. The second to fourth defendants submitted that the permission to serve the claim outside the jurisdiction should be set aside on the basis of material non-disclosure in the affidavit relied upon in support of the application. Specifically, they submitted that the claimant had not disclosed a submission made by them in the French proceedings that the deceased's domicile at the time of his death had been French, nor the fourteen factual allegations relied upon by them in that respect.

The court ruled:

(1) A will was to be interpreted in accordance with the law intended by the testator. In the absence of indications to the contrary, that was presumed to be the law of his domicile at the time when the will was made. However, that was a rebuttable presumption. It might be apparent from the nature of the will or other matters that the testator had written his will with reference to and with the intention that it should be interpreted according to the law of some other country.

The will in the instant case had to be interpreted according to the law intended by the deceased. The circumstances made it absolutely clear that, whatever his domicile might have been, he had intended his will to be interpreted according to the laws of England. As a matter of English law, its meaning was clear. Clause 6(b) was expressed to be subject to clause 6(a). Under that clause, and in the event that the disposition under clause 6(a) did not take effect, the deceased gave his shares in the two SCIs to the second to fourth defendants and the balance to his godson. However, the first defendant had satisfied the condition in clause 6(a) by surviving the deceased by 56 days. Accordingly, the disposition under clause 6(a) had taken effect. Inevitably therefore, the disposition under clause 6(b) had not taken effect. Accordingly, the claimant was entitled to summary judgment.

(2) In the circumstances, England was clearly the most appropriate forum for the dispute to be heard. The will was an English document, drawn by an English solicitor and expressed in technical terms of the law of England. It had to be interpreted according to English law. The substantive issues were straight-forward and could be determined in England without any further evidence at all. Indeed, the claimant was entitled to judgment. Notwithstanding that the defendants were resident in France and were French nationals, and that the instant case related to shares in a French company, overall, England was the forum with which the dispute had the most real and substantial connection. Accordingly the application to strike out or stay the claim on the basis that England was not the convenient forum had to be dismissed.

(3) The dispute over the domicile of the deceased at the time of his death and the fourteen factual allegations relied upon by the second to fourth defendants in support of the submission that his domicile at that time had been French should have been disclosed. Nevertheless, in the particular circumstances of the instant case, it would not be right to set the order aside. It had not been suggested that the claimant had deliberately misled the court, and the issue could not affect the outcome of the other matters. It would be contrary to the overriding objective to make an order which would simply introduce unnecessary complexity into the proceedings.
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7. Ledger v Wootton and another

Citation: [2007] All ER (D) 99 (October)
Court: Chancery Division
Judge: Norris J
Hearing date: 8 October 2007
Summary: will – testator – soundness of mind – testamentary capacity

The deceased died in February 2004, leaving a will under which half of her modest estate was left to the defendants, two of her five children. The remaining half was bequeathed to her grandchildren, including the claimant's three children. The deceased had a history of mental illness. The claimant applied for revocation of the grant of probate and sought the grant of letters of administration to herself on the basis that the deceased had died intestate.

The claimant contended that the deceased lacked capacity at the time the will was made as, on the balance of probabilities, she suffered from a paranoid personality disorder. The defendants did not advance a positive case but simply put the claimant to proof.

The application would be allowed.

The evidence did not establish that a particular delusion suffered by the deceased directly influenced the actual terms of her will, but it did raise the possibility that a defect in her mind interfered with a consideration of matters that should have been taken into account on the making of a will. In light of the defendants' failure to put a positive case, the compelling conclusion was that the deceased lacked capacity at the date the will was made.

The issue concerning the grant of letters of administration would be adjourned.
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8. Hogg v Otford Tool & Gauge Co Ltd

Citation: [2007] All ER (D) 54 (October)
Court: Chancery Division
Judge: Lindsay J
Hearing date: 4 October 2007
Summary: equity – undue influence – actual undue influence

The claimant in both actions was the son of W. The defendants in the first action were the sisters of the claimant (the first and second defendants). The defendant company, of which W had been the lifetime chairman, in the second action (the company) had been founded by W. The claimant had been appointed a director of the company in 1968. In 1992, he ceased to be a director and set up his own rival business. He was assisted in the running of that business by S. Ultimately, the business failed and, in 1998, the claimant returned to the employment of the company. On 8 April 1992, W and his wife, I, made a settlement of the total issued share capital in the company (the share settlement). That settlement was made with a view to mitigating the effects of inheritance tax. The principal beneficiaries under the share settlement were the first and second defendants. The claimant was irrevocably denied present and future ownership of any part of the then issued share capital in the company. I died in 1999. On 5 December 2001, W settled his freehold house on trust (the squirrels settlement). The claimant and the first defendant were appointed as trustees and, following the death of W the property was to be held in equal fifth shares for the three siblings in default of any alternative disposition by W in his will or any codicil thereto. On 24 December, W created a further trust (the Gosport settlement) of which the claimant and the first defendant were the trustees and principal beneficiaries. As W grew older, the first defendant provided care for him, in return for which she received a salary from the company. On 7 December 2004, W executed deeds of removal and exclusion in relation to both the squirrels settlement and the Gosport settlement. The net effect of those deeds (the impugned transactions) was that the claimant ceased to be a trustee and beneficiary of each of the settlements. Subsequently, the claimant issued the first action by which he alleged that the impugned transactions had been procured by the undue influence exercised over W by the first defendant. By the second action, the claimant sought the payment of remuneration said to be owed to him by the company. The company counterclaimed for the repayment of funds advanced to the claimant's director's loan account which it alleged had been applied for his personal benefit.

The claimant submitted, inter alia, that W had not understood the nature and effect of the impugned transactions, nor had he wished their consequences. The first defendant had used her forceful personality and her position as W's carer to influence him into executing the transactions. The defendants submitted, inter alia, that no such influence had been exercised upon W. His exclusion of the claimant had been borne from a desire to safeguard the future of the company which W believed could have been at risk, particularly in the light of the claimant's relationship with S, a man of whom W had a great mistrust and dislike.

The court ruled:

(1) On the evidence, the claimant had failed to demonstrate that the impugned transactions were occasioned by or the consequence of undue influence exercised over W by the first defendant. The evidence tended to show that W had acted freely in deciding to exclude the claimant from the settlements, and the motivation to so exclude was properly justifiable upon W's mistrust of the claimant's relationship with S, and his desire to safeguard the future of the company as a family business. Moreover, the fact that W had excluded the claimant from benefiting under the share settlement was indicative of a previous willingness on the part of W to exclude the claimant, absent any allegation undue influence. Accordingly, the first action would be dismissed.

(2) In the second action, the claimant had failed to demonstrate that he was owed any remuneration from the company. In relation to the counterclaim, the sums sought by the company were not properly ascertainable in the instant proceedings. In those circumstances, the counterclaim would remain undetermined, save that a specific sum relating to a payment made in respect of the claimant's liability arising from his failed business was not recoverable on the basis that the claimant had had no actual or constructive knowledge of that payment.

Royal Bank of Scotland v Etridge (No 2) and other appeals; Barclays Bank plc v Coleman; Bank of Scotland v Bennett; Kenyon-Brown v Desmond Banks & Co (a firm) [2001] 4 All ER 449 applied.

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Features

1. Inheritance tax  changes

Peter Penneycard, a tax expert at accountants and business advisers PKF, points out that the changes in the pre-budget report have actually doubled the inheritance tax threshold to £600,000 with incremental increases to £700,000 by 2010.

This has been achieved by allowing up to double the nil rate band on the death of the surviving spouse, based on the value in effect at the date of the second death, but only if the double nil band is preserved at the time of the first death. If the nil band is used on the first death, the £50,000 increase scheduled for 2010/11 is lost and taxed at 40  per cent and £20,000, is paid needlessly.

Widows or widowers may also now be able to leave more assets to their families tax-free even if their spouse died many years ago and they have remarried.

"The changes to inheritance tax have made many established tax planning techniques redundant with couples who already have inheritance tax-saving plans in place which use the allowance at the time of the first death, potentially leaving their beneficiaries paying £20,000 more in tax," says Mr Penneycard.

"The rules are complex and the terms of everyone's will and their trusts, if they have them, are different. The important thing is to recognise that the tax regime has changed significantly and for the better, but that they may need to act now to ensure their families derive the maximum benefit when they die," he says.

Mr Penneycard says that the changes affect anyone with an estate worth more than £300,000 and increasingly when that figure gets towards and over £600,000.

"The massive rise in the housing market in recent years means hundreds of thousands of people will be affected and should review the existing terms of their wills with a tax specialist," he says.

"Older couples may also wish to defer making lifetime gifts to the next generation until after the first death to reduce the risk of freezing part of their combined nil rate bands if the donor dies within seven years of the gift."

Mr Penneycard believes that forward planning is the key to reaping the benefits from the system and not lose out. To ensure that beneficiaries inherit the maximum amount of what is left for them, he recommends consulting a specialist to make sure all angles are covered.

"In many instances there is flexibility in the terms of a trust so that it can either be implemented or not, depending on what is most beneficial. My best advice is to have it looked at with an expert and be safe, or your beneficiaries may end up being sorry if you fail to plan in light of the changes."
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2. IHT counterpunch

Chancellor Darling has proposed an inheritance tax (IHT) threshold increase for married couples and civil partnerships of £600,000 rising to £700,000 to supplement the current inter-spouse/partner exemption.

Jon Golding of LexisNexis Butterworths and author of Tolley’s Inheritance Tax says: "On the face of it the inheritance tax proposal from Mr Darling this afternoon appears to be a counterpunch to the Conservatives £1 million nil rate band threshold suggestion.

"By increasing the IHT threshold, with immediate effect, to £600,000 and rising to £700,000 for married couples and civil partnerships only, seems to be generous, but recent statistics do show that less marriages are taking place with more couples choosing to live together. It will however take many estates out of IHT net when married couples pass on their homes to, say, their children, but it will only apply when the survivor spouse dies!

"This is a delayed tax saving. Even the immediate IHT benefit for widows and widowers of their deceased partner’s IHT threshold will only be of help when that surviving spouse dies … this may be in many years time especially with the increasing longevity of the United Kingdom’s population. Those that will lose out are people living together so, maybe, a key tax planning suggestion for the future will be to get married and save an additional £120,000 in IHT."

Transfers of capital between spouses has always been exempt from IHT, but the surviving spouse, having inherited the deceased spouse’s assets, could only have benefit of their nil rate band, despite having inherited the assets of their deceased spouse. This, therefore, meant that there were other ways sought of passing on the deceased partner’s assets to the children so utilising the nil rate band. In the past, there was always the option for married couples to set up a nil rate band discretionary trust to avoid the loss of nil rate band of the pre-deceased on the second death.

These forms of trust will still be used as they give flexibility to disposals and control of assets by Trustees. The small size of some estates was such that this meant that this planning technique was not possible. With this new IHT proposal for married couples and civil partnerships the survivor spouse/partner can now inherit and subsequently have benefit on death of the spouse’s nil rate band without having to resort to using the nil rate band trusts.

Many cohabiting couples are under the misapprehension that their relationship is a “common law marriage” with the appropriate protections afforded married couples and, now, civil partnerships. In fact the concept of common law marriage rights has not existed since the protection under “common law” marriages, which was abolished as far back as 1753. These IHT proposals by Mr Darling will not apply to cohabiting couples.
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Articles

1. Move over, Darling

Journal name: Taxation
Author: Allison Plager and Richard Curtis
Citation: Taxation, 18 October 2007, 424
Issue date: 18 October 2007
Summary: Discusses the Conservative party's proposal to increase in the inheritance tax exemption to £1 million a few weeks ago. Labour criticised it as uncosted and unaffordable. However, the Government recently announced that, with immediate effect, that is, from 9 October 2007, any unused inheritance tax nil rate band on a person's death will be transferable to the surviving spouse or civil partner.
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2. Expect the unexpected

Journal name: Pensions World
Author: Peter Tompkins
Citation: Pensions World, October 2007, 37
Issue date: 01 October 2007
Summary: Asks whether trustees should allow members to update their nominations. There are perhaps two reasons for this. The first is that if a death benefit is paid under discretionary trust, the Revenue authorities have always allowed it to be paid free of tax. Secondly, giving the trustees sole right to decide who the money is to be paid to can make it much easier to get a quick payment out of the pension scheme, at a time when the dependants may be struggling to liberate funds from other sources before probate.

Please note subscribers can go to LexisNexis Butterworths for further details about all the above articles. Non-subscribers can sign up for a free trial of the online service.

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Books

1. How to book and claim discounts
  • Law Society Publishing: quote “Probate Section” to receive a 20 per cent discount off related titles (excluding directories) via Prolog at The Law Society, PO Box 99, Sudbury Suffolk CO10 2SN, telephone 0870 850 1422, fax 01787 313 995 or email lawsociety@prolog.uk.com.
  • LexisNexis Butterworths: quote “Law Society Section discount offer” when ordering via www.lexisnexis.co.uk, customer.services@lexisnexis.co.uk or 020 8662 2000.

This e-alert is not intended to provide comprehensive records of information concerning the probate sector. If you have any feedback or suggestions, please email probatesection@lawsociety.org.uk. This e-alert was created in conjunction with LexisNexis UK Legal Updater Service. For further information about any of the articles, please contact sabina.smith@lexisnexis.co.uk. The views expressed by the Legal Analysis interviewees are not necessarily those of the proprietor.
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