IHTA84/S144 applies where property comprised in a person's estate immediately before death is settled on discretionary trusts by their will, and

within two years of that person's death, and

before any interest in possession has subsisted in the property (where the testator dies on or after 22 March 2006, an interest in possession here means only an immediate post death interest or a disabled person's interest (IHTM16060)),

an event occurs which

would prima facie give rise to a proportionate charge or flat rate charge (for example, an event resulting in the deceased's widow becoming beneficially entitled would be such a chargeable occasion), or

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