Summarising the issues:
Value of estate lies primarily in the property value of c£500,000; it is intended to change ownership status to tenants in common.
We are advised that we should create a discretionary nil rate tax band trust whereby on first death the one-half share of the property passes to the sole beneficiary [son] but the surviving spouse can continue to reside in the property paying a nominal £1 per year rent and also to take a 'loan' from the Trust equal to the value of the amont transferred into the trust. The loan will be repayable with interest on the death of the second spouse.
Does this make sense please? Are there other tax implications regarding the transaction - CGT? Income tax? Thanks.
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