The results of the Phizackerley test case on the issue of Inheritance Tax and nil-rate band will trusts, is just the start of a "long war" with HM Revenue & Customs on the subject of tax planning, claims the Royal Bank of Canada.
In February the Special Commissioners ruled in favour of HMRC in the test case on the basis the amount of money – approximately £153,000 – Dr Phizackerley owed to the nil-rate band trust set up by his wife, to hold her share of the family home, was originally his. As a result there has been much speculation within the industry on how this affects nil-rate band trusts and the circular transfer of money, with some suggesting people have to die in the right order to avoid IHT. The Royal Bank of Canada, says the outcome of the 'Phizackerley' case may have implications for thousands of cou...
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