Discretionary Will Trust-exit charge

[beckied]

Discretionary trust created through Will (death November 2007). Shares qualifying for 100% BPR settled as a result. Subsequent reorganisation which resulted in share exchange, loan notes and cash. Cash subsequently appointed to one of discretionary beneficiaries in July 2016. Rate of tax based on gross value of shares (ie before BPR) at date of death as exit before 10 year anniversary but presumably also need to take into account any failed PETs (which became chargeable lifetime transfers) made by settlor in 7 years prior to start of Will trust?

[LozaACCS]

Yes, but have you recognised the CGT position on the cash (and possibly loan notes) on the reorganisation.