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The now infamous changes to the inheritance tax treatment of trusts, introduced in the 2006 Budget, ...

The now infamous changes to the inheritance tax treatment of trusts, introduced in the 2006 Budget, took most, if not all, practitioners by surprise. These changes extended the 'relevant property regime' (basically the discretionary trust regime) to most trusts. The inheritance tax consequences of membership of the relevant property regime include potential charges on establishment, 10-yearly anniversaries and transfers of capital to beneficiaries. The harshness of the new regime was somewhat lessened by providing a 'period of grace' during which affected trusts could be restructured. ...

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