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A further examination

12 January 2010
Issue: 4238 / Categories: Forum & Feedback , Inheritance Tax
'I do not agree with the application of IHTA 1984, s 43'

In A detailed examination Simon McKie analysed an inheritance tax product using a series of endowment policies assigned into trust. He referred to a product provided by an Isle of Man based insurance company.

I am familiar with the product in question as indeed I was with at least one of its predecessors. I believe that inventive insurance solutions of this type can offer helpful assistance in formulating an estate planning strategy for clients. 

I was therefore surprised to read Mr McKie’s concerns about both the technical efficacy of the arrangement and HMRC’s view of it. These observations seem to fall into two primary categories.

The first is that a policy as a whole is assigned into trust and must be viewed as a single asset.

The second is that despite providing clear guidance on the treatment of life assurance products that guidance is fatally...

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