Trust trouble

My unmarried client wishes to minimise the inheritance tax liability arising on his death and proposes to transfer into a trust of which he will be the sole trustee £325 000 now and the relevant nil-rate band amount every seven years thereafter.

The trust will be for the benefit of his domestic partner who will have no right to any enjoyment of the trust fund until the death of my client whereupon she will become absolutely entitled to the whole of the property and its accumulated income.

In the event of her predeceasing him the trust property and its accumulated income will revert to him.

My client is aware of the ten-year anniversary charge but I am wondering if the value subject to that charge could be nil or reduced being an interest that is either reversionary (i.e. future contingent) and therefore excluded property...