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  • May 11, 2026

Partner and Senior Associate co-author article on IHT cap for excluded property trusts

Private Client Partner Kate Johnson and Senior Associate Caroline Russell have co‑authored an article for Business & Accountancy Daily examining the government’s inheritance tax cap on excluded property trusts.

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The article explores the significant changes to the taxation of trusts that took effect from April 2025, including the move to a residence‑based inheritance tax regime. While the introduction of a £5m cap on relevant property charges offers some relief for certain trusts, Kate and Caroline highlight that trustees are still faced with a complex planning landscape shaped by long‑term residence tests, tail periods and ongoing compliance requirements.

The piece also sets out the key issues trustees should be considering now, including record‑keeping, asset location, the timing of distributions and the impact of new anti‑avoidance provisions.

Read the full article in Business & Accountancy Daily here [£].

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