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CONTENTS IN DETAIL
Page
Foreword
Preface
Trusts Discussion Forum
A Note to the Lay Reader
Drafting Quotations
Table of Cases
Table of Statutes
Table of International Legislation
Table of Abbreviations
Trust Terminology
PART 1 — TRUST DRAFTING
Chapter 1: The Finance Act 2006: The Raid on Trusts
Policy of Finance Act 2006 1.1
Misconceptions 1.2
Policy issues 1.3
Trusts after the Finance Act 2006 1.4
Existing trusts after the Finance Act 2006 1.5
Duty to the client 2.1
Elderly or ill client 2.2
Does drafting matter? 2.3
Flexibility 2.4
Simplicity 2.5
Sources for drafting 2.6
(1) Statute 2.7
(2) Law reports 2.8
(3) Company law 2.9
(4) Legal literature and precedent books 2.10
Formal qualifications for the drafter 2.11
Money laundering 2.12
Civil claims against the drafter 2.13
Introduction 3.1
Punctuation 3.2
Use of capitals 3.3
Sentence length 3.4
Must every clause be a single sentence? 3.5
Indentation 3.6
Passive voice 3.7
General comment 3.8
Numbers: words or figures? 3.9
Style of clause numbering 3.10
Dates 3.11
Addresses 3.12
Age 3.13
Singular and plural 3.14
Male and female 3.15
And/provided that/but 3.16
Deemed/treated as 3.17
Archaic and prolix expressions 3.18
Clause headings 3.19
Incorporation by reference 3.20
Artificial rules of construction 3.21
The class closing rule 3.22
The rule in Lassence v Tierney or Hancock v Watson 3.23
Cross-references 3.24
Obsolete forms 3.25
“For her separate use” 3.26
Entails 3.27
Trusts for sale 3.28
Chapter 4: Principles of interpreting trust documents
Introduction 4.1
General principle 4.2
Factual background/previous negotiations/declarations of intent 4.3
Meaning of words v meaning of document 4.4
The objective principle 4.5
Deemed intention 4.5.1
Intention irrelevant 4.5.2
Relationship between objective principle and inadmissibility rules 4.6
Relationship between objective principle and literal construction 4.7
Arguments for and against the objective principle 4.8
Relationship between objective principle and rectification 4.9
Precedent not the solution 4.10
Conclusion 4.11
Are principles of construction of wills or trusts the same as contracts
or statutes? 4.12
“Construction not restricted by technical rules” 4.13
Too much money 5.1
Profligacy 5.2
A protective trust? 5.3
A better solution 5.4
Insolvency of a beneficiary 5.5
Before or after the bankruptcy order is made 5.6
Before the bankruptcy order is made 5.7
Anti-creditor clauses 5.8
Divorce of beneficiaries 5.9
(1) Dealing with beneficiary’s equitable interest 5.10
(2) Interest under the trust as a financial resource 5.11
(3) Variation of settlement on divorce 5.12–5.13
Divorce of beneficiaries: conclusions 5.14
Anti-alimony forms 5.15
Foreign domiciled beneficiary 5.16
Marriage under 18 5.17
Definition of “Beneficiaries” 5.18–5.19
Children and descendants 5.20
“Children of X and Y” 5.21
Illegitimate beneficiaries 5.22
Adopted beneficiaries 5.23
Stepchildren 5.24
Assisted reproduction 5.25
Children by surrogacy 5.26
Spouses of beneficiaries 5.28
Civil partners 5.29
Settlor and spouse/civil partner as beneficiaries 5.31
Meaning of “spouse”/“civil partner” of settler 5.32
Settlor’s surviving spouse/civil partner as beneficiary of lifetime trust 5.33
Testator’s spouse/civil partner as beneficiary of will 5.34
Separated spouse/civil partner of settlor as beneficiary 5.35
Charities as beneficiaries 5.36
Non-charitable companies as beneficiaries 5.37
Foreign charities as beneficiaries 5.38
Power to add beneficiaries 5.39
Power to exclude beneficiaries 5.40
Other possible beneficiaries 5.41
Dependants 5.42
Employees of beneficiaries 5.43
Employees of family company 5.44
“Fall back” beneficiaries 5.45
Charity as “fall back” beneficiary 5.46
Distant relatives as “fall back” beneficiaries 5.47
Use of default clause 5.48
Simple addition to the class of beneficiaries 5.49
Limited extension of the class of beneficiaries 5.50
Tax and the class of beneficiaries 5.51
Number of trustees 6.1
Choice of trustees 6.2
Beneficiaries as trustees 6.3
Professional trustees 6.4
Corporate trustees 6.5
Accountants as trustees 6.6
Director of listed company as trustee 6.7
Insider dealing and trusteeship 6.8
Custodian trustees 6.9
Foreign trustees 6.10
Order of trustees’ names 6.11
Flee clauses 6.12
Conflicts of interest 6.13–6.14
Distinguishing personal and fiduciary conflicts 6.15
Trustee-beneficiaries 6.16
Construction of trustee exemption clauses 6.17
“Free from responsibility for loss” 6.18
“No liability for loss” 6.19
“In the professed execution of the trusts and powers hereof” 6.20
“Absolute owner” “beneficial owner” clauses 6.21
Validity of exemption clauses 6.22
Should the drafter insert an exemption clause? 6.23
Duty to disclose exclusion clauses to settlor/testator 6.24
Drafting an exemption clause 6.25
Commentary: should exemption clauses be allowed? 6.26
What standard of care rests on trustees? 6.27
Excluding strict liability 6.28
Excluding claims by unknown beneficiaries 6.29
Relying on counsel’s advice 6.30
Excluding duty to supervise family companies 6.31
Excluding duty to supervise parents and guardians 6.32
Appointment of new trustees 6.33
Who appoints trustees? 6.34
Appointment of foreign trustees 6.35
Retirement of trustees 6.36
Two trustees requirement 6.37
Further provisions concerning appointment of additional trustees? 6.38
Trustees’ right to resign 6.39
Sections 19 and 20 Trusts of Land and Appointment of Trustees
Act 1996 6.40
Power to dismiss trustees 6.41
Short form 6.42
Introduction 7.1
Duties and powers distinguished 7.2
Duties or powers: does it matter? 7.3
Powers and duties: terminology 7.4
Drafting duties and powers 7.5
Other usage of “shall” and “may” 7.6
Provisions about how often and when powers are exercised 7.7
Should discretionary duties have time limits? 7.8
Powers exercisable “at any time” and “from time to time” 7.9
“Absolute discretion” and “as the trustees think fit” 7.10–7.11
Guidance and control of trustees 7.12
Majority decisions 7.13
Two-trustee rule 7.14
Statement of wishes 7.15
Drafting the statement of wishes 7.16
Power of appointment of new trustees 7.17
Consultation with beneficiaries 7.18
Control of trustees 7.19
What trustees’ powers should be subject to control? 7.20
What sorts of checks can be made on trustees’ powers and who
exercises them? 7.21
Giving powers of appointment to beneficiaries personally 7.22
Giving powers of consent to beneficiaries 7.23
Giving powers of consent to the settler 7.24
Giving powers of appointment to a settlor 7.25
Better methods of controlling trustees 7.26
Settlor (or spouse) as sole trustees? 7.27
Weighted majority clause 7.28
Protectors 7.29
Power to dismiss trustees 7.30
Dealing with the former trustee 7.31–7.32
Nature of powers of consent and appointment 7.33
Particular assets 8.1
Shares and securities in a private company 8.2
Leasehold property 8.3
Land subject to mortgage 8.4
Life insurance policies 8.5
Chattels 8.6
Property qualifying for IHT business/agricultural property relief 8.7
Property situate outside England and Wales 8.8
Chapter 9: The rule against perpetuities
Introduction 9.1
Which perpetuity period? 9.2
Drafting 9.3
Confusion over dates 9.4
Trust period and perpetuity period distinguished 9.5
(1) Dispositive powers 9.6
(2) Beneficiaries’ interests 9.7
Effect of failure to remain within perpetuity period 9.8
Future of the rule against perpetuities 9.9
Chapter 10: General provisions of a trust
Order of provisions 10.1
Declaration of trust or transfer to trustees? 10.2
Title 10.3
Date 10.4
On what date does a trust take effect? 10.5
Backdating 10.6
Parties 10.7
Who should be parties? 10.8
Describing the parties 10.9
Form where settlor is one of the trustees 10.10
Form where trust made by joint settlers 10.11
Form where settlor is sole trustee 10.12
No named settlor 10.13
Nominal settlor 10.14
Recitals 10.15
Recital 1: A list of the principal beneficiaries of the trust 10.16
Recital 2: Name of trust 10.17
Power to change name of trust 10.18
Recital 3: Foreign domicile of settlor 10.19
Useless recitals 10.20–10.25
Testatum 10.26
Definitions 10.27
Beneficial provisions 10.28
Testimonium clause 10.29
Schedule of trust property 10.30
Schedule of administrative provisions 10.31
Schedule of beneficiaries? 10.32
Definitions 10.33
How to make definitions 10.34
“Define as you go” 10.35
A definition clause 10.36
“Means” and “includes” 10.37
Unnecessary forms in a definition clause 10.38
Some standard definitions 10.39
Definition of “the trustees” 10.40
Definition of “the trust fund” 10.41–10.42
Unnecessary definitions 10.43
Definitions implied by law 10.44
Definitions to break up text 10.45
Drafting successive interests 10.46–10.47
Irrevocability 10.48
Chapter 11: Drafting and understanding overriding powers
(appointment, re-settlement and advancement)
Introduction 11.1
Power of appointment 11.2
Unnecessary provisions in the power of appointment 11.3–11.4
The problem of narrow powers of appointment 11.5
Power of resettlement 11.6
Power of resettlement and power of appointment compared 11.7
Power of advancement 11.8
Power to pay or transfer to beneficiary 11.9
Power of appointment used to make advance to beneficiary 11.10
Power of advancement used to create new trusts 11.11
Chapter 12: Exercising overriding powers
Who should draft deeds of appointment? 12.1
How to instruct counsel 12.2
Drafting deeds of appointment 12.3
Useful recitals 12.4
Appointment creating royal lives clause 12.5
Some points to watch in drafting deeds of appointment 12.6
Example deed of appointment 12.7
Points to watch in drafting transfers to another settlement 12.8
Example exercise of power to transfer to another settlement 12.9
Who should draft settled advances? 12.10
Drafting resolutions of advancement 12.11
Example resolution of advancement used to alter terms of trust 12.12
Example resolution of advancement used to transfer property to
two separate settlements 12.13
Example resolution of advancement used to transfer property from
one settlement to another 12.14
Procedure after execution of deed of appointment/resettlement/
advancement 12.15
Chapter 13: Settlor exclusion and default clauses
Why exclude the settlor and spouse/civil partner? 13.1
CGT hold-over relief 13.2
Excluding the settlor: drafting 13.3
(1) Direct benefit 13.4–13.5
(2) Resulting trust 13.6
(3) Power to benefit settlor 13.7
(4) Actual benefit 13.8
(5) Reciprocal arrangements 13.9
Settlor exclusion clause 13.10
When is a settlor exclusion clause appropriate? 13.11
What does a settlor exclusion clause cover? 13.12
Drafting the settlor exclusion clause 13.13
Joint settlors 13.14
Exclusion of additional and indirect settlors 13.15
Reference to “spouse” in settlor exclusion clause 13.16
Unnecessary provisions in settlor exclusion clause 13.17
No reservation of benefit 13.18–13.20
“No resulting trust for the settlor” 13.21
Dependent children exclusion clause 13.22
Default clause 13.23
Drafting the default clause 13.24
Unnecessary provisions in a default clause 13.25
Correcting errors in a default clause 13.26
An unnecessary default clause 13.27
Chapter 14: Lifetime interest in possession trusts
Introduction 14.1
Why use interest in possession trusts? 14.2
Interest in possession income clause 14.3
Structure of lifetime interest in possession trust 14.4
Income to the principal beneficiary for life 14.5
Provisions after death of the principal beneficiary 14.6
An alternative: beneficiary’s power to appoint to widow/civil partner 14.7
Describing the widow 14.8
A perpetuity problem 14.9
Position after death of surviving spouse/civil partner 14.10
Future accumulation of income 14.11
IP forms for two life tenants 14.12
Commentary on straightforward flexible form 14.13
An inflexible form 14.14
Objection to simple accruer clause 14.15
Life tenant becomes entitled at specified age 14.16
Life tenant a minor 14.17
Interest in possession for settlor 14.18
Impeachment for waste 14.19
Chapter 15: Discretionary trusts
Meaning of discretionary trust 15.1
Why use discretionary trusts? 15.2
Discretionary trust: income clause 15.3
Distribution limb 15.4
Accumulation limb 15.5
The rule against accumulations 15.6–15.7
Other accumulation periods? 15.8
Strategies for trustees after accumulation period expires 15.9
Structure of discretionary trust 15.10
“Beneficiaries” 15.11
Powers of discretionary trusts 15.12
Chapter 16 : Provisions inconsistent with IP and IHT special trusts
Administrative, dispositive, beneficial: terminology 16.1
Significance of administrative/dispositive distinction 16.2
When is a provision administrative or dispositive? 16.3
Power to pay capital expenses out of income 16.4
Retention of income to provide for liabilities or depreciation
of a capital asset 16.5–16.6
Capital/income and apportionment provisions 16.7
Power of appropriation 16.8
IP trusts: “departure” v “disqualifying” powers 16.9
Power to pay insurance premiums out of income 16.10
Power to permit beneficiary to occupy or use trust property rent free 16.11
Power to lend money interest free 16.12
Power to waive income 16.13
IHT special trusts 16.14
Power to permit beneficiary to occupy or use trust property rent free 16.15
Power to use income to pay life insurance premiums 16.16
Protection clauses 16.17
Drafting and construction of protection clauses 16.18
Interest in possession protection clause 16.19
“No conflict” clause 16.20
CGT protection clause 16.21
A & M protection clause 16.22
Chapter 17: Types of will trusts
Types of will trusts: terminology 17.1
Spouses : terminology 17.2
IPDI trusts: qualifying conditions 17.3
Why use IPDI trusts? 17.4
Terms of IPDI trust after death of life tenant 17.5
Age 18-to-25 trusts: qualifying conditions 17.6
Why use Age 18-to-25 trusts? 17.7
Bereaved Minors trusts 17.8
“Express Wills” 17.9
Will trusts and lifetime trusts: drafting differences 17.10
Foreign trustees 17.11
Survivorship clauses 17.12
Gift by will to existing trust 17.13
Chapter 18: Will drafting after the Finance Act 2008
Introduction 18.1–18.2
Classic NRB trusts 18.3
Will drafting after the Finance Act 2008 18.4
How transferable NRBs work 18.5
NRB claims 18.6
Transfer of NRB in cases of remarriage 18.7
Untransferable NRB problems 18.8
Choice of will trusts: overview 18.9
Best form of will for single testator 18.10
Best form of will for testator who is married or a civil partner 18.11
Married testator: provision for children by will 18.12
The nil rate formula 18.13
Construction of traditional nil rate band formula where
transferable NRB applies 18.14
Terms of classic NRB trust 18.15
Alternatives to nil rate band trusts 18.16
Married testator with business or agricultural property 18.17
Best forms of will making substantial gifts to charity 18.18
Best form of will for foreign domiciled testator 18.19
Best form of will for UK domiciled testator with foreign
domiciled spouse 18.20
Existing wills containing a classic NRB trust 18.21
Chapter 19: Administration of Nil Rate Band Trusts
Introduction 19.1
Appropriation of share of family home 19.2
Position if house worth less than nil rate sum 19.3
Trust law issues 19.4
Implementation of debt scheme 19.5
Administration of the NRB trust 19.6
Limitation considerations 19.7
Subsequent sale of property 19.8
Winding up the NRB trust after the death of the spouse 19.9
Tax implications of repayment or release of the debt 19.10
Chapter 20: Wills and care fee planning
Introduction 20.1
Why use will trusts? 20.2
Types of trust 20.3
Assessing liability to pay 20.4
Valuation 20.5
Capital disregards 20.6
Deprivation of capital 20.7
Administration of the will trust after the survivor goes into care 20.8
Chapter 21: Administrative provisions
Introduction 21.1
Unnecessary provisions 21.2
Power to insure 21.3
Power to vary investments 21.4
Power to add powers 21.5
Power to accept additional funds or onerous property 21.6
Powers relating to accounts and audits 21.7
Powers to deal with shares and debentures 21.8
Power to repair and maintain trust property 21.9
Unnecessary forms relating to administrative powers 21.10
Restricting administrative powers to perpetuity period 21.11
“In addition to the statutory powers” 21.12
Trustees entitled to expenses of exercising powers 21.13
Other provisions 21.14
Void powers 21.15
Power to determine questions of fact or law or “matters of doubt” 21.16
Power to make determinations subject to jurisdiction of court 21.17
Power exercisable with consent of court 21.18
Which powers should the drafter include? 21.19
STEP Standard Provisions 21.20
Standard administrative provisions 21.21
Power of investment 21.22–21.23
Power of joint purchase 21.24
General power of management and disposition 21.25
Power to improve trust property 21.26
Provisions relating to the income/capital distinction 21.27
Power to pay capital expenses out of income 21.28
Power to apply trust capital as income 21.29
Rent: income or capital receipt? 21.30
Sinking funds 21.31
Equitable apportionment 21.32
The balance between income and capital 21.33
Demergers 21.34
Occupation and use of trust property 21.35–21.36
Loans to beneficiaries 21.37–21.38
Trust property as security for beneficiaries’ liabilities 21.39
Power to trade 21.40
Power to borrow 21.41
Delegation 21.42
Nominees and custodians 21.43
Power to give indemnities 21.44
Power to give security for trustees’ liabilities 21.45
Power of appropriation 21.46
Receipt by charities 21.47
Release of rights and powers 21.48
Ancillary powers 21.49
Provisions relating to minors 21.50
Power to retain income of child 21.51
Administrative provision for mentally handicapped beneficiaries 21.52
Power to disclaim 21.53
Statutory apportionment 21.54
Trustee remuneration 21.55
Standard charges and conditions 21.56
Commissions and bank charges 21.57
Excursus: trustee charging clauses 21.58
Layman’s work 21.59
Informing the client 21.60
Remuneration of corporate trustee 21.61
Trustee remuneration clause: dispositive or administrative 21.62
Status of remuneration clause for other purposes 21.63
Can the settlor charge if he is a trustee but there is a settlor
exclusion clause? 21.64
Trustee/director remuneration 21.65
Terminology 22.1
Why use bare trusts? 22.2
Tax advantages 22.3
Non-tax aspects of bare trusts 22.4
Draft bare trust 22.5
Additions to bare trust 22.6
Chapter 23: Trusts of life insurance policies
Introduction 23.1
Insurance company standard form 23.2
Trusts created pursuant to contract of insurance 23.3
Trust created over existing policy 23.4
IHT implications of using a trust 23.5
Ten-year charges and exit charges during lifetime of settlor 23.6
Tax returns 23.7
Advantages of multiple discretionary trusts 23.8
Some drafting points 23.9
Precedent trust for life policy 23.10
Introduction 24.1
Some general comments 24.2
Name 24.3
Trustees 24.4
Exclusion of settlor and non-charitable purposes 24.5
Rule against accumulation 24.6
Administrative provisions for charities 24.7
Trading 24.8
Remuneration of charity trustees 24.9
Procedure after execution of charitable trust 24.10
Charitable will trusts 24.11
Benefit “disregard” of trust of damages 25.1
Trust of damages for adult with mental capacity 25.2
Jurisdiction to transfer child’s damages to bare trust 25.3
A precedent bare trust for child 25.4
Consequences of using bare trust 25.5
Creation of a substantive trust of child’s damages by compromise 25.6
Trusts for minors: commentary 25.7
Trusts of damages for person lacking mental capacity 25.8
Award under Criminal Injuries Compensation Scheme 25.9
Chapter 26: Trusts for disabled beneficiaries
Mentally handicapped beneficiaries 26.1
Choosing provisions for disabled beneficiaries 26.2
Welfare benefits 26.3
Tax reliefs for disabled beneficiaries 26.4
IHT dependent relative relief 26.5
Actual estate-IP for disabled beneficiary 26.6
Disabled Person Trap 26.7
Actual estate-IP for prospectively disabled settlor 26.8
IHT deemed IP for disabled beneficiary 26.9
IHT deemed IP for prospectively disabled settlor 26.10
CGT full annual allowance 26.11
Mixed trusts 26.12
CGT hold-over relief 26.13
Income tax/CGT transparency: disabled beneficiary 26.14
Drafting requirement 26.15
Income tax/CGT tax transparency: orphan beneficiary 26.16
Effect of income tax/CGT transparency relief 26.17
Disabled beneficiaries: conclusion 26.18
Small funds 26.19
Substantial funds: provision by will 26.20
Substantial funds: lifetime provision 26.21
Commentary 26.22
Chapter 27: Governing law, place of administration and jurisdiction clauses
The governing law 27.1
Selection of English governing law 27.2
Selection of foreign governing law 27.3
Power to change the governing law 27.4
Place of administration of trust 27.5
Exclusive jurisdiction clause 27.6
“Forum of administration” 27.7
Chapter 28: Restricting rights of beneficiaries
Restrictions on disclosure of information 28.1
Disclosure of Will 28.2
Beneficiary’s right to trust information 28.3
No named beneficiaries or unascertainable default beneficiary 28.4
Extension of powers of disclosure 28.5
No-contest clauses 28.6
Non-assignment clauses 28.7
Chapter 29: Execution of wills and trust deeds
Review of draft 29.1
Review and approval by parties 29.2
Use and misuse of precedents 29.3
Caution! Word processor at work 29.4
Printing 29.5
Natural decay 29.6
Fraudulent alterations 29.7
Procedure on execution of a lifetime settlement 29.8
(1) Transfers of trust property to trustees 29.9
(2) Statement of wishes 29.10
(3) Arrangements for payment of IHT on gift in case
of death within seven years 29.11
(4) Arrangements for loss of nil rate band in case of
death within seven years 29.12
(5) Return and other matters 29.13
Stamp duty and SDLT 29.14
Procedure on execution of a will 29.15
Tax reviews after execution of trust 29.16
Chapter 30: Appointment and retirement of trustees
Powers of appointment/retirement 30.1
Review by new trustees before accepting trusteeship 30.2
Review by appointor and retiring trustees before appointing new
trustees or retiring 30.3
Drafting an appointment/retirement of new trustees 30.4
Provisions of deed 30.5
Unnecessary clauses in deed of appointment 30.6
Vesting trust property in new trustees 30.7
Stamp Duty and SDLT 30.8
Chapter 31: Indemnities for executors and trustees
Introduction 31.1
Trust law indemnities 31.2
Right of trustees to retain trust property as security. 31.3
Right of trustee to refuse to retire. 31.4
Right of executors 31.5
Right of former trustees 31.6
Limits on trust law indemnities 31.7
Are express indemnities needed? 31.8
Negotiating indemnities 31.9
Conflicts of interest 31.10
Indemnity from beneficiaries 31.11
Indemnity from new trustees 31.12
Indemnity for breach of trust 31.13
Time limit to indemnity 31.14
Cap on amount payable under indemnity 31.15
Death of new trustee 31.16
Retirement of new trustee 31.17
Multiple trustees 31.18
Security for indemnity 31.19
Proper law and jurisdiction clause 31.20
PART 2 — PRECEDENTS
Precedents for Lifetime Trusts
Interest in possession trust for adult beneficiary
Discretionary trust
Charitable trust
Precedents for Will Trusts
1. Discretionary will trust
2. Life interest for surviving spouse/civil partner
3. Life interest for surviving spouse/civil partner with absolute gift of nil rate sum
4. Life interest for surviving spouse/civil partner with nil rate band discretionary trust
5. Nil rate band discretionary trust; residue to surviving spouse/civil partner absolutely
6. NRB discretionary trust; residue to: (1) surviving spouse/civil partner absolutely (2) discretionary trust (if no surviving spouse/civil partner)
7. NRB discretionary trust; residue to partner (not spouse/civil partner) absolutely
Precedents for Administrative Provisions
NRB appointment 1: winding up unwanted NRB trust
NRB appointment 2: reducing gift to NRB trust to untransferable NRB
NRB appropriation and appointment (implementing NRB appropriation scheme)
NRB Spouse Undertaking
NRB Charge over half share of land
Settlor appointor
NT1 Retirement and appointment of new trustee
NT2 Appointment of new trustee after death of trustee (Companion CD only)
NT3 Appointment of additional trustee (Companion CD only)
NT4 Retirement without appointment of new trustee (Companion CD only)
Trustees are appointors
NT5 Retirement and appointment of new trustee (Companion CD only)
NT6 Appointment of new trustee after death of trustee(Companion CD only)
NT7 Appointment of additional trustee (Companion CD only)
NT8 Retirement without appointment of new trustee
Appendix 1: STEP Standard Provisions
Appendix 2: Annotated Bibliography
Appendix 4: NRB Debt and charge arrangements: tax analysis
Appendix 5: Tax on payment of index linked nil rate sum
Appendix 6: Share of house in trust: CGT Private Residence Relief
Appendix 7: Definitions of “disabled” for tax purposes
Appendix 8: Notes on the translation of will precedents into Welsh
Index
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