Thai’d-up property

I have a client in his late 70s who has a substantial property portfolio of approximately £3m with very large inherent capital gains.

The client has two sons from his first marriage and in 2007 he married a Thai woman who is in her 50s.

He wishes to pass the majority of the properties to his sons but is faced with large capital gains tax liabilities and on his death substantial inheritance tax liabilities.

I recently had a meeting with my client to discuss his tax affairs generally and he has informed me that his current thinking is that he will pass all his properties to his wife on his death.

The plan is that she will then make gifts of most of those properties to his sons.

There is obviously an element of trust involved in this plan and she would of course have...