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Lifetime Transfer

Forums › Ask ACCA Tutor Forums › Ask the Tutor ACCA TX-UK Exams › Lifetime Transfer

  • This topic has 0 replies, 1 voice, and was last updated 4 years ago by AverageAndy.
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  • July 16, 2020 at 7:37 am #576948
    AverageAndy
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    • Topics: 128
    • Replies: 34
    • ☆☆

    sir from a tax planning point of view i am interested to know if the 7 yr CLT history that we look at (to deduct that from our current NRB), is that of the trustee or donor?

    Because let’s say donor is a rich man and frequently transfers a huge chunks of his wealth through CLTs, so his NRB would get used up very fast. So for future CLTs he would have to pay lifetime tax on full amount of CLTs(in case where donor has to pay lifetime tax). But if instead trustee’s CLT history is looked at and he has made no CLT in the last 7 yrs, then it makes sense for the donor to ask trustee to take onus of lifetime tax, because it is going to be *Nil(full NRB available to trustee), anyway.

    This way donor ends up saving tax, and despite trustee being responsible for payment of lifetime tax(IHT) does not have to pay any tax(gross CLT becomes net CLT).

    * Assume CLT amount=NRB amount

    Is that right sir???

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