Readers' forum : Trust tangles

I have recently been approached to act for a trust. It was created in 1984 as an accumulation and maintenance trust for the settlor’s two children born in 1981 and 1987. Under the terms interests in possession were created on the beneficiaries’ 18th birthdays and the vesting age for each of them is 30. The assets held within the trust are shares in an unlisted investment company.

My query concerns the capital taxes issues relating to a deed of variation created in January 2011 where the date of vesting of capital has been deferred to January 2064. By delaying the vesting age is there a resettlement with the settlors being the children? If that is the case this would presumably make the current settlement a relevant property trust – as opposed to an interest in possession – and I would therefore need to consider periodic and...