In general, for IHT purposes, the capital value of a trust will either:

be treated as forming part of the taxable estate of the beneficiary entitled to the trust income (in the case of bare trusts, immediate post-death interest trusts; disabled trusts; transitional serial interests or lifetime interest in possession trusts established before 22 March 2006); or

in the case of all other trusts (other than charitable trusts) be taxed independently as trust property every ten years or when property leaves the trust under the relevant property rules.

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