The case law must be viewed against the estate duty background in which all property except UK personalty bore its own tax. The question most often before the court was: has incidence been shifted from the property itself on to residue? Following the decision in Cowie's Trustees, Petitioners [1982] BTC 8072 and IHTA 1984, s. 211, it is now much more likely that tax will fall upon residue in any event, and there may be less scope for dispute between beneficiaries.

Need help? Get subscribed!

To subscribe to this content, simply call 0800 231 5199

We can create a package that’s catered to your individual needs.

Or book a demo to see this product in action.